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Consolidated Return Update

NEW PROPOSED REGULATIONS FROM THE IRS PROVIDE TAXPAYER-FRIENDLY SOLUTIONS TO ISSUES WITH TAX RETURN DUE DATES AND CIRCULAR ADJUSTMENT TO BASIS. In the last six months, the U.S. Department of the Treasury has issued two...more

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

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

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

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

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