Business Organization Tax

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Proposed 2704 Regulations Attack Valuation Discounts

The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...more

Proposed Rules Would Limit Valuation Discounts for Family Controlled Entities

On August 2, 2016, the Internal Revenue Service proposed regulations that would severely limit valuation discounts for lack of marketability and lack of control that taxpayers have historically applied for federal gift,...more

What Makes A 401(k) Plan A Target For Litigation

I’ve always been a big fan of 1970’s cinema and one forgotten classic is The Sting, starring Paul Newman, Robert Redford, and Robert Shaw. The title to the movie refers to the exact moment when the con artist finishes the...more

Section 501(c)(4) Organizations Subject to IRS Notice Requirement

Nonprofit entities that intend to operate as tax-exempt organizations described in section 501(c)(4) of the Internal Revenue Code (Code) are subject to new reporting requirements with the IRS. Specifically, newly-enacted...more

China Tax Newsletter - May / June 2016

In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. On the PRC side, following the national rollout of the...more

IRS Proposes Rules That Would Dramatically Reduce Valuation Discounts in Family Business Succession Planning

Business Owners May Have Little Time to Act Before Rules Are Finalized - The valuation of a family member's interest in a family business has a major impact on the success or failure of a transfer of such interest to...more

Changes to business rates: how could they affect you?

A recent announcement by the Valuation Office Agency (VOA) and draft regulations released by the Department for Communities and Local Government (DCLG) are set to introduce changes that are likely to increase business rates...more

Client Alert: New Safe Harbors for Management Contracts of Tax-Exempt Financed Facilities

The Internal Revenue Service on August 22, 2016 released Revenue Procedure 2016-44 which revises the safe harbor guidelines for management contracts of service providers for tax-exempt financed facilities, under which the...more

Blog: Court Gives Energy Transfer the Right to Walk Based on its Counsel’s Inability to Deliver the Required Tax Opinion

In a rare decision involving unusual facts, the Delaware Court of Chancery held that a buyer (Energy Transfer Equity, L.P.) had the right to terminate a signed merger agreement with its target (The Williams Companies, Inc.)...more

Maryland Tax Court Overturns Comptroller's Policy of Limiting Subtraction for Interest Received on Federal Obligations

The Maryland Tax Court recently ruled that a bank was entitled to deduct all of its interest received with respect to federal obligations for Maryland corporate income tax purposes, thereby generating net operating losses...more

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

IRS Issues New Management Contract Safe Harbors

Almost 20 years ago, the IRS released Rev. Proc. 97-13, outlining multiple safe harbors under which a management contract would not result in private business use of bond-financed proceeds. These safe harbors, while helpful,...more

IRS Proposes Regulations That Will Eliminate Most Valuation Discounts on Family-Owned Entities

On August 2, 2016, the IRS issued proposed regulations that would eliminate or limit the use of certain valuation discounts regularly applied when valuing interests in family-owned entities for gift and estate tax...more

IRS Proposes New Regulations That Will Significantly Limit the Use of Valuation Discounts on Transfers of Interests in Closely...

The proposed regulations disregard restrictions that have been used by valuation experts and acknowledged by the courts to reduce valuations. If you are an owner of a closely held entity, recently proposed Treasury...more

Proposed Section 2704 Regulations

On August 2, 2016, the Treasury Department released proposed regulations amending and expanding upon the current regulations to Internal Revenue Code Section 2704. The proposed regulations, if adopted, would affect the...more

IRS Guidance on Section 457: What Non-Profit and Governmental Employers Need to Know (Part 2)

We're back with the second installment in our series on the IRS's Section 457 proposed rules. The first alert covered Section 457(f) basics and discussed the meaning of "deferred" compensation....more

IRS Issues Proposed Regulations Affecting Valuations of Family-Owned Companies

On August 2, 2016, the IRS released Proposed Regulations under section 2704 of the Internal Revenue Code of 1986 (“Code”). Those Proposed Regulations, which were published in the Federal Register August 4, 2016, make...more

Proposed IRS regulations will limit valuation discounts for family-held entities

On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more

Proposed IRS Rules Endanger Business Valuation Discounts for Family-Owned Entities

Historically, the IRS has closely scrutinized transfers of interests in family-owned entities between family members. In particular, it has sought to curtail the use of discounts to decrease the estate and gift tax value of...more

Is an S Election for an LLC Smart Planning or a Bad Idea?

By default, a limited liability company (“LLC”) with two or more members is taxed as a partnership. It also is possible to elect to treat an LLC as an S corporation for income tax purposes. But is it a good idea? And if an S...more

Treasury Issues Proposed Regulations Limiting Valuation Discounts on Transfers of Family-Controlled Entities

The Treasury Department recently issued long-awaited proposed regulations regarding valuation discounts of interests in corporations and partnerships for estate, gift and generation-skipping transfer tax purposes. If...more

Newly Released Proposed Regulations under Section 2704 Apply Broadly to Disallow Valuation Discounts for Transfer Tax Purposes,...

Overview - On August 4, 2016, the Treasury Department issued much anticipated proposed regulations under §2704 of the Internal Revenue Code, which, if finalized in their current form, will make very significant changes...more

IRS and Treasury Issue Regulations on “50(d) Income” Affecting Tax Credit Deals

The Internal Revenue Service and Department of Treasury recently issued final and temporary regulations on income inclusion under Section 50(d) of the Internal Revenue Code as it relates to the tax credit industry. The...more

Proposed Regulations May Substantially Reduce the Availability of Valuation Discounts for Interfamily Transfers of Business...

On August 2, 2016, the Treasury Department published Proposed Regulations to Chapter 14 of the Internal Revenue Code which, if adopted, may substantially reduce the availability of valuation discounts for inter-family...more

Treasury Issues Proposed Regulations Limiting Valuation Discounts on Transfers of Family-Controlled Entities

The Treasury Department recently issued long-awaited proposed regulations regarding valuation discounts of interests in corporations and partnerships for estate, gift and generation-skipping transfer tax purposes. If...more

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