Justin G. Crouse Justin G. Crouse

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Justin G. Crouse focuses his practice on US and international tax matters. He has collaborated with clients from a range of industries to research and develop international tax planning opportunities, including global holding company structures, intellectual property migration, foreign tax credit planning and repatriation. Read Justin Crouse's full bio.

Despite NOL Carrybacks, IRS Continues to Deny Refunds of Section 965 Transition Tax Overpayments


By on Apr 29, 2020
Posted In Tax Refunds, Uncategorized

In a series of frequently asked questions (FAQs) addressing the interaction of recently enacted net operating loss (NOL) carryback provisions and section 965, the IRS stated that taxpayers may not receive a refund of any section 965 tax payment unless and until the payment exceeds the “entire income tax liability for section 965.” The IRS...

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Tax Blog: New Questions and Answers for Section 965


By and on Jul 19, 2019
Posted In IRS Guidance, Tax Reform, Tax Refunds, Uncategorized

The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or triggering events, and other matters related to S corporation shareholders making the section 965(i) election. Consistent with prior advice issued by the IRS (see coverage...

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Section 965 Transition Tax Overpayment Addressed in Technical Corrections


By and on Jan 4, 2019
Posted In IRS Guidance, Tax Reform, Tax Refunds, Uncategorized

On January 2, 2019, the outgoing Chair of the House Ways and Means Committee, Kevin Brady (R-TX), released the Tax Technical and Clerical Corrections Act (the Bill), addressing several technical issues associated with the Tax Cuts and Jobs Act (P.L. 115-97) (TCJA). The Bill includes certain provisions that, if enacted, would affirm Congress’ intent that...

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Tax Reform Insight: Congress Offers a Glimmer of Hope for Taxpayers with Section 965 Transition Tax Overpayment


By and on Dec 19, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

Recently proposed legislation would provide taxpayers who made an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through installment payments the ability to claim a refund or credit of any overpayment with respect to such amounts. If enacted, taxpayers would be able to claim a refund or...

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A Look at Treasury’s Recent Efforts to Reform Regulation


By and on Jun 7, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

Just 10 days after his inauguration, President Trump signed Executive Order 13771, establishing the tenet of deregulation to be adopted by the Trump administration. Executive Order 13771 outlined the Trump administration’s vision for reducing regulation and controlling regulatory costs, and established a principle that for every one new regulation issued at least two prior regulations...

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Treasury Releases Report on Regulatory Reform Accomplishments


By and on Apr 30, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On April 24, 2018, the US Department of the Treasury (Treasury) released a report (Report) outlining the efforts undertaken to-date by Treasury to implement the president’s regulatory reform agenda.  The efforts have been in furtherance of President Trump’s Executive Order 13771 and Executive Order 13789 calling for a reduction in regulatory burdens and costs. The...

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GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders


By , , , and on Feb 1, 2018
Posted In Tax Reform, Uncategorized

The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts who own CFC stock (either directly or through LLCs or S...

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Treasury Releases Report on Reducing Tax Regulatory Burdens


By and on Oct 5, 2017
Posted In IRS Guidance, Uncategorized

On October 2, 2017, the US Department of the Treasury (Treasury) submitted a report (Report) to the President of the United States recommending the withdrawal, revocation or revision of eight Treasury Regulations in order to eliminate or otherwise mitigate the “burdens imposed on taxpayers.” This action springs from Executive Order 13789 issued by the President...

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