IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS -
Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more
2/3/2016
/ Certiorari ,
ConAgra ,
Dividends ,
FIRPTA ,
Foreign Currency ,
Income Taxes ,
IRS ,
Market Basket ,
Political Candidates ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
RICs ,
SCOTUS ,
Tax Court ,
Tax Refunds ,
Withholding Tax
Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly:
On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more
11/4/2015
/ Business Assets ,
Capital Gains ,
Comment Period ,
Dividends ,
Fair Market Value ,
FATCA ,
Final Rules ,
Guidance Update ,
Investment Adviser ,
Investment Companies ,
Investment Management ,
IRS ,
Limited Partnerships ,
Management Fees ,
Market Basket ,
New Guidance ,
Partnerships ,
Property Transaction Taxes ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Spinoffs ,
Tax Liability ,
Third-Party Service Provider ,
Transfer Pricing ,
Transfers ,
U.S. Treasury ,
Vanguard ,
Waivers ,
Whistleblowers
IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest -
On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more
8/7/2015
/ De Minimus Quantity Exemption ,
Derivatives ,
Dodd-Frank ,
Excise Tax ,
FATCA ,
IRS ,
Life Insurance ,
Partnerships ,
Retrocession Contracts ,
Senate Finance Committee ,
Tax Court ,
Tax Reform ,
U.S. Treasury
Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more
In This Issue:
- IRS Rules Debentures Are Part of Straddle; Interest Non-Deductible
- Stock Abandonment Produces Ordinary Loss
- Tax Consequences of Negative Interest Rates
- Renewed Discussion of a...more
In This Issue:
- Congress Passes Year-End Tax Extenders Bill
- House Adopts New “Dynamic Scoring” Rule
- Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more
In This Issue:
- IRS Clarifies Deadline for Correcting Withholding Documentation
- Consent Payment Modifying Contingent Payment Debt Instrument Must be Tested for Significance
- IRS Concludes Correction of Error...more