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
The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more
4/25/2013 - Foreign Corporations International Tax Competitiveness Act of 2013 International Tax Issues Offshore Companies Proposed Legislation Stop Tax Haven Abuse Act
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
On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp...more
1/30/2013 - Camp Draft Capital Gains Derivatives Hedge Funds Income Taxes
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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