Tax Business Organization

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IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more

PA Supreme Court Declares Portion of Slot Machine Tax Unconstitutional; Provides Possible Preview of Pending NOL Cap Case

The Pennsylvania Supreme Court finds municipal share assessment unconstitutional. The Court held that the municipal share assessment, imposed on slot machine revenue, is a non-uniform progressive rate structure that violates...more

It's Time For Your Buy-Sell Checkup!

Shareholders, Partners and/or LLC members of any closely-held or family-held company should check the buy-sell formula contained in their Shareholder Agreement (sometimes called a Buy-Sell Agreement), Partnership Agreement or...more

Comparison of Clinton and Trump Tax Proposals

As the 2016 Presidential Election approaches the Democratic and Republican candidates and their staff are busy refining and promoting their respective economic and tax reform proposals. While neither candidate is proposing a...more

ADOR Proposes Substantial Rule Change For Partnerships

The ADOR has proposed a number of amendments to its rule governing the filing of partnership tax returns, Form 65. The new rule, as proposed, inserts language conforming with Alabama’s recently enacted “factor presence nexus”...more

Global Tax News: Brazil opens consultation on how MAP provisions apply to DTT agreements

Brazil’s Federal Revenue (RFB) has opened a public consultation aimed at regulating how mutual agreement procedure (MAP) provisions apply to conventions and international agreements created to avoid double taxation....more

IRS to Update 1967 Revenue Ruling Relating to Change of Domicile

The Internal Revenue Service (the “IRS”) has announced plans to update Revenue Ruling 67-390, which requires an organization to “re-apply” for tax-exemption if it changes its corporate structure, including in situations...more

Criminal consequences of the use of leaked data by tax authorities

Leaks of confidential information are becoming more common. Businesses and individuals may face scrutiny by investigative agencies following leaks of information from third parties or by employees. Businesses in particular...more

IRS Proposes Regulations That Would Increase Wealth Transfer Taxes in Family-Controlled Entities

The Internal Revenue Service (IRS) proposed regulations on August 2, 2016, under which transfers to family members of interests in family-controlled entities — including partnerships, limited liability companies (LLCs) and...more

Exclusion for Qualified Small Business Stock

The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings to small business owners and non-corporate...more

Global Tax News: Brazil amends lists of tax havens and tax privileged regimes, clarifies "substantial economic activity"

Earlier this month, Brazil’s Federal Revenue (RFB) released Normative Instruction RFB No. 1,658, which amended Normative Instruction RFB No. 1,037/2010 to...more

Global Tax News: Hard times in the oil patch: tax implications for investors in the era of price fluctuations

The current decline in oil prices, which continues to show no signs of a long-term reversal, is having a great many unexpected and unwanted consequences, many of which may turn into long-lasting troubles for the oil and gas...more

Demystifying Phantom Equity

Phantom equity is a colorful term for a simple concept: compensation that rewards key contributors for increasing the value of the company without the immediate issuance (or even any future issuance) of equity securities....more

Three Restatements Conclude with SEC Enforcement Action

Following a restatement of its financial statements, many firms are investigated by the SEC and later named in an enforcement action. For Weatherford International PLC, three was the charm – following its third restatement in...more

Proposed regulations will significantly impact the valuation of interests in many family-controlled entities

New rules have been proposed by the Internal Revenue Service (IRS) which would regulate the valuation of transfers of business interests between family members. Based upon recent interpretation, it appears that the IRS is...more

Proposed IRS Regulations Could End Most Valuation Discounts for Family Entities

On August 2, 2016, the Treasury Department issued proposed regulations under Section 2704 of the Internal Revenue Code. The proposed regulations, if adopted in their current form, essentially will eliminate all minority...more

Proposed Regulations Under IRC Section 2704 Seek to Eliminate Discounts on Transfers of Family Business Interests

On Aug. 2, 2016, the Treasury Department and the Internal Revenue Service released proposed regulations under Internal Revenue Code (Code) section 2704 (the “Proposed Regulations”). The Proposed Regulations, if finalized in...more

Estate Planning Valuation Discounts Under Section 2704: An Update

For about a generation, families have taken minority discounts when valuing interest in closely-held businesses for estate, gift and generation-skipping transfer tax purposes. This popular estate planning technique is often...more

The Qualified Subchapter S Subsidiary Election – A Primer and Beyond

Mr. Brant’s article offers readers a broad overview of the QSub election and a review of the history surrounding its statutory creation. In addition, it provides a rather in-depth discussion of the QSub qualification...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Kübler-Ross and IRS Announcement 2016-32

When the IRS announced that it would virtually eliminate the determination letter program for individually designed retirement plans, many practitioners moved through the classic Kübler-Ross five stages of grief. Some have...more

How 401(k) Plan Sponsors Can Improve Their Plan At Little Cost

There are many ways that a retirement plan sponsor can improve their 401(k) plan, but they usually balk when it comes to the time and the money needed to rectify it. With so many issues regarding their business especially the...more

Notice Requirements for Social Welfare Organizations

Section 501(c)(4) of the Internal Revenue Code (“IRC”) exempts from the federal income tax certain nonprofit corporations that are operated exclusively for the promotion of social welfare (commonly referred to as “Social...more

IRS Proposes Valuation Discount Regulations: Implications for Family-Controlled Businesses

IRS issues new proposed rules aimed at eliminating valuation discounts for transfers of interests in family-controlled entities. Clients considering making transfers of interests in such entities should act soon....more

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