Todd Reinstein

Todd Reinstein

Pepper Hamilton LLP

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Rev. Proc. 2014-24 Provides Taxpayers Relief When Missing Form 1122 On Joining A Consolidated Group

On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more

3/26/2014 - Consolidated Tax Returns Corporate Taxes IRS

Final Regulations Issued For Transfers Of Built-In Loss Property

On August 30, 2013 the Treasury Department released final regulations regarding guidance on Section 362(e)(2), preventing the duplication of loss when property containing a net built-in loss is transferred to a corporation in...more

1/16/2014 - Section 351 Section 362 Tax Deferral U.S. Treasury

IRS Issues Favorable Final Section 382 Regulations On Small Shareholders; Might Be Time To Revisit Your 382 Study

The Treasury and IRS issued Final Treasury Regulations to address the treatment of small shareholders under Section 382 on October 21, 2013. These regulations address a number of concerns expressed over the years about the...more

1/16/2014 - Corporate Taxes IRS Net Operating Losses Shareholders U.S. Treasury

Recent Taxpayer-Friendly Section 199 Guidance On Benefits And Burdens Of Ownership

Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more

9/4/2013 - Income Taxes QPAI Section 199 Tax Benefits Tax Deductions

New Regulations Provide Advantageous Acquisition Structures

New regulations issued by Treasury under Section 336(e) permit certain stock acquisitions to be treated as asset purchases, allowing buyers access to stepped-up asset basis and corresponding depreciation and amortization...more

7/17/2013 - Acquisitions Amortization Asset Purchaser Depreciation Mergers Section 336(e) Stock Options Tax Deductions U.S. Treasury

IRS Taking Tough Stand On Benefits And Burdens Of Ownership In Recent Section 199 ILM And Tax Court Cases

On April 1, the Internal Revenue Service (IRS) released ILM 201313020 (ILM) in response to an IRS Appeals Division request. It concludes that planning and development activities undertaken by a publisher of books and other...more

5/8/2013 - Domestic Production Gross Receipts IRS QPAI Section 199

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