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At Last: Final Regulations Issued Under Section 336(e)

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under ยง336(e) (the Final Regulations) on May 10. Section 336(e)...more

5/14/2013 - Corporate Taxes Distribution Rules IRS Proposed Regulation Stocks

Legal Alert: One Shade of GRA: Proposed Regulations Foreshadow the End of the GRA Directive and Provide That "Available Upon...

On January 30, Treasury and the IRS issued proposed regulations relating to the proper filing of gain recognition agreements (GRAs) and other related compliance obligations (the Proposed Regulations). As a general matter, a...more

2/5/2013 - Directors Federal Reserve Gain Recognition Agreements IRS Stocks

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

1/8/2013 - Alternative Minimum Tax American Taxpayer Relief Act Business Taxes Capital Gains Dividends Estate Tax Fiscal Cliff Foreign Corporations Generation-Skipping Transfer Gift-Tax Exemption Income Taxes Production Tax Credit Roth Conversions Withholding Tax

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