Ellen McElroy

Ellen McElroy

Pepper Hamilton LLP

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Latest Publications


Tax Developments Affecting Health Care Organizations (Presentation)

In this Issue: •Income recognition issues associated with bundled payment arrangements •Income recognition related to electronic health records •Developments involving the nonaccrual experience method of...more

4/17/2014 - Bundled Payments Data Protection EHR Healthcare PHI

Final Regulations Released Revising The Tax Treatment Of Sales-Based Royalties And Vendor Allowances

In December 2010, the IRS and Treasury proposed regulations that required the allocation of sales-based royalties and vendor allowances exclusively to property that has been sold (or for inventory property, deemed sold under...more

4/1/2014 - IRS Royalties Sales U.S. Treasury Vendors

New IRS Guidance Offers Insight Regarding Covered Transactions Under the Transaction Cost Regulations

When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally...more

4/1/2014 - Acquisitions Covered Transactions IRS Private Letter Rulings Safe Harbors

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more

3/31/2014 - IRS Property Tax Safe Harbors Tangible Property Tax Deductions U.S. Treasury

Construction Is Complete On Much Of The Repair Regulations

On September 13, 2013, the IRS and Treasury Department released final regulations regarding the deduction and capitalization of expenditures related to tangible property. Rules were also released regarding accounting for and...more

9/16/2013 - IRS New Regulations Property Improvements Repairs Tax Deductions U.S. Treasury

IRS Issues Clarification As To The Taxability Of Gift Card Sales

It has been estimated that annual gift card sales have reached approximately $110 billion as a result of an increase in gift card offerings from financial services firms (for example, American Express, Visa, MasterCard and...more

9/4/2013 - Financial Products Gift-Cards Income Taxes IRS

IRS Rules That A Partially Tax-Free Transaction Qualifies As ‘Covered Transaction’ For Purposes Of The Transaction Cost...

The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5....more

7/17/2013 - Compliance Corporate Sales Transactions Corporate Taxes IRS Tax Reform Tax Returns Tax-Free Exchanges

New Directive Correctly Resolves Use Of Transaction Cost Safe Harbor For Milestone Payments – Questions Nonetheless Linger

A new directive specifies that Large Business & International (LB&I) examiners should not challenge a taxpayer’s treatment of eligible milestone payments when success-based fees are incurred, provided a safe harbor election...more

5/8/2013 - IRS Milestone Payments Safe Harbors Transaction Costs

IRS ‘Repairs’ The Examination Of Tangible Property Regulation Issues

In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more

5/7/2013 - Future Tax Treatment IRS Proposed Regulation Tangible Property

Tax Issues Stirred Up by Hurricane Sandy

In late October, Hurricane Sandy caused significant damage to many businesses throughout the Northeastern United States. In the past, business taxpayers experiencing similar storm damage would have focused primarily on the...more

12/3/2012 - Hurricane Sandy IRS Property Damage

IRS Defers Effective Date for Repair Regulations

In Notice 2012-73,1 the IRS announced that its regulations will be amended to delay the effective date of the 2011 temporary tangible property regulations (T.D. 9564) (the 2011 Regulations), which were to apply to tax years...more

12/3/2012 - IRS

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