In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more
In This Issue:
- Deferred Earnings and Profits of CFCs
- Code Section 956(e)
- Code Section 7701(l)
- Code Section 304(b)(5)(B)
- Code Section 7874
- Request for Comments
-...more