Tax Finance & Banking

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
News & Analysis as of

DOL Releases Final Regulations to Expand ERISA ‘Fiduciary’ Definition

In Depth - After more than five years of development and revision, the US Department of Labor (DOL) released final regulations to redefine a “fiduciary” under the Employee Retirement Income Security Act of 1974, as...more

New Guidance on Bad Boy Guarantees

The IRS Office of Chief Counsel recently released a memorandum (#AM2016-001) addressing the proper tax treatment of nonrecourse carve-outs (or bad boy guarantees) in the partnership context. According to the memorandum, such...more

Pennsylvania Audits Public Companies for Unclaimed Securities

Holders that use third-party transfer agents, such as Computershare, should check their mailboxes, as they are likely to have a notice from Pennsylvania of an unclaimed property audit. Pennsylvania has engaged...more

Taxpayer Entitled to Section 1033 Gain Exclusion Despite Holding Only a Beneficial Ownership Interest in Condemned Property

In PLR 201609003, the IRS determined that a taxpayer was entitled to exclude gain attributable to the forced transfer of the taxpayer’s ownership of public use facilities, even though the taxpayer did not hold legal title to...more

HM Treasury Consults on Legislation for Secondary Annuities Market

HM Treasury published a consultation paper on the UK Government’s proposed secondary market due to be introduced in April 2017. The market would extend the recently introduced pension freedoms and flexibilities to...more

2015-16 New York State Budget

On April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below....more

More DB DC Plan Design Flexibility in Maximizing Benefits for Highly Compensated Employees

Given the subject matter involved, this Alert is very technical and specialized. If your company offers both an active pension plan and a 401(k) or profit sharing plan and performs the general test to satisfy the...more

Section 385 Proposed Regulations

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

A Compilation of Non-Enforcement Actions

Non-Enforcement - Amendments to the Venture Capital Fund Adviser and Private Fund Adviser Exemptions - Last month the SEC’s Division of Investment Management issued a guidance update (Update) addressing recent...more

Partnerships Must Respond to New Audit Rules

The recently-enacted Bipartisan Budget Act of 2015 includes a far-reaching overhaul of the rules applicable to IRS partnership audits and tax adjustments. This will be significant for partnerships and limited liability...more

Tax Law Blog: Prince's Estate Plan (or lack thereof)

News sources are reporting that court documents filed last week indicate Prince died intestate, meaning he did not have a will. His sister filed the paperwork, stating to her knowledge he did not have a will and requesting...more

The Rosenbaum Law Firm Review - May 2016

The New Fiduciary Rule: What It Means To Plan Sponsors - Bottom line: what does it mean? If you're a retirement plan sponsor and, unless you've been living under a rock, you've probably heard about the Department...more

April 30 Deadline to Restate Pre-Approved Plans

Sponsors of pre-approved defined contribution retirement plans are generally required to sign new plan documents that incorporate changes required by the Pension Protection Act on or before April 30, 2016. Defined...more

IRS Rules Could Treat Related Party Debt as Stock

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Brokerage Account is a Safe Account to Temporarily Hold Homestead Sale Proceeds for Reinvestment [Florida]

An individual sold his interest in a Florida homestead, and put a portion of the proceeds in two Wells Fargo brokerage investment accounts entitled “Fl. homestead account..” The account was invested in mutual funds and unit...more

PA Property Tax Reassessment Update

Several counties in Pennsylvania are conducting countywide property reassessments. This update provides status changes for Washington, Blair and Lancaster Counties, along with a set of important deadlines and basic assessment...more

New Jersey Issues Guidance on BEIP Grant Conversion

This month the New Jersey Economic Development Authority (the Authority) provided businesses with guidance, in the form of Frequently Asked Questions, on how to elect to have their unpaid Business Employment Incentive Program...more

Only the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations

The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more

Is it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis

Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more

IRS Confirms California “Waiting Time Penalties” Are Not Wages For Federal Income Tax Purposes

A recent IRS information letter confirms that “waiting time penalties” paid under California law are not wages for federal income tax withholding purposes. Section 203 of the California State Labor Code imposes penalties on...more

New Proposed Regulations Increase Scrutiny on Related-Party Debt

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

Tax and Non-Tax Reasons to be Cautious about “Bad Boy Nonrecourse Carve-out Guarantees” - IRS Backtracks on Recent Conclusion that...

On April 15, 2016 the IRS reversed its controversial position that bad boy guarantees may convert nonrecourse debt into recourse debt. General Legal Advice Memorandum Number AM2016-001 released April 15, 2016 effectively...more

Burr Alert: Is Tennessee "Retiring" Its Hall Income Tax?

Tennessee has long been known as a retirement friendly state and usually ranks in the Top 10 of any list identifying the best places in the U.S. for retirement. That reputation is about to be enhanced as Tennessee's...more

WCO TCCV approves case study on TNMM transfer pricing documentation and customs valuation

During the week of 18-22 April 2016 the World Custom's Organizations Technical Committee on Customs Valuation (TCCV) held its 42nd Session in Brussels. At this session a new instrument was approved by the TCCV that contains a...more

Obligation to Perform Work and Incur Costs Under Construction Contract is a Section 752 Liability

In a recently issued Private Letter Ruling (PLR 201608001), the IRS determined that a taxpayer-partnership’s obligation to perform work and incur costs under a long-term construction contract constituted a partnership...more

4,988 Results
|
View per page
Page: of 200

Follow Tax Updates on:

JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×