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Tax Business Organization

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

by Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

Groundbreaking—IRS makes things complicated

Employers who adhere to certain IRS guidelines may face much lower indemnity payments for employees who traveled for work pre-injury - Myres v. Strom Aviation, Inc. (16-558) - In companies where employees regularly...more

End and refund of the French 3% tax on distributions

by White & Case LLP on

The French Constitutional Court rules that the 3% contribution on distributions is unconstitutional - On 6 October, 2017, the French Constitutional Court, in its decision (n°2017-660 QPC), held that the 3% contribution on...more

IRS Proposes Update and Streamlining of Public Approval Under TEFRA

by Miles & Stockbridge P.C. on

The Internal Revenue Service (the “IRS”) and The U.S. Department of the Treasury (the “Treasury”) proposed regulations on September 28, 2017 to update and streamline the public approval requirement applicable to tax-exempt...more

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor

The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more

[Webinar] Defined Value Clauses; S Corp. Distribution of Property; Traps Donating a Business to Charity - October 31st, 12:00pm CT

by Thompson Coburn LLP on

In this webinar the presenter will discuss defined value clauses to reduce risk when transferring hard-to-value assets, the consequences of converting from an S corporation to a partnership, and issues to consider when...more

S-corporations – Time to Roll In your Rental-Income Benjamins

by Miles & Stockbridge P.C. on

In Private Letter Ruling 201725022 (the “PLR”), the IRS determined that rental income an S-corporation received from its operations is not passive investment income that would subject the S-corporation to termination. In...more

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

by Carlton Fields on

A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

Are Your Business Deductions at Risk of Being Disallowed by the IRS?

by M. Robinson & Company, P.C. on

Small businesses run on tight margins. The last thing a business owner wants is an IRS notice announcing the disallowance any of their business expense deductions. This is particularly the case for sole proprietorships who...more

Criminal Finances Act 2017 – New Criminal Offence Requires Preventive Procedures

by McDermott Will & Emery on

The UK Criminal Finances Act 2017 recently introduced a new corporate offence of failure to prevent the facilitation of tax evasion. Under the new law, a corporate body or partnership may be criminally liable if it fails...more

Checking The Box, Partnership Allocations, And Foreign Law

by Farrell Fritz, P.C. on

Many of our clients, most of which are closely-held U.S. businesses, are looking to expand their operations overseas. Some are venturing into foreign markets on their own, while others are joint-venturing with established...more

IRS and Treasury Department to Withdraw Proposed Tax Regulations Curbing Valuation Discounts

by Davis Wright Tremaine LLP on

In a positive development for closely-held business owners and their families, the Treasury Department recently recommended the complete withdrawal of its proposed tax regulations that would have severely limited the...more

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

The Truth And Myth Over The 401(k) Investment Policy Statement

by Ary Rosenbaum on

When you go to kitchenware, you see so many different types of kitchen tools that you didn’t know existed. They sell pasta forks and cherry pitters and item you don’t really need, but you have to have. When you’re a 401(k)...more

Treasury to Withdraw Controversial Section 2704 Proposed Regulations

by Baker Donelson on

The Treasury Department announced on October 2, 2017 that it plans to withdraw proposed regulations under I.R.C. Section 2704 ("Proposed 2704 Regulations") that would have reduced or eliminated certain valuation discounts for...more

IRS Ruling Provides Helpful Guidance on Normalization Proration Rules 

On September 29, 2017, the IRS issued a private letter ruling (PLR 201739001) providing helpful guidance on the application of normalization proration rules for the calculation of accumulated deferred federal income taxes...more

Tax Planning is Crucial to Achieve Potential Spin-Off Benefits

by Proskauer - Tax Talks on

Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions. The Journal article notes that the S&P Spin-Off Index has outperformed the S&P 500...more

Section 2704 Regulations to be Withdrawn

by Williams Mullen on

On August 2, 2016, the Treasury Department issued proposed regulations under Internal Revenue Code Section 2704. The proposed regulations, through a web of dense rules and definitions, would have narrowed longstanding...more

Treasury Report Proposes Substantial Revisions to Controversial Tax Regulations

by Morrison & Foerster LLP on

Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more

TechConnect - Your Law Firm Link to Industry News - September 2017

by Mintz Levin on

Letter from the Editors - Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more

New Jersey Tax Court: Limited Partner has Nexus with New Jersey

by Reed Smith on

In a decision released today, the Tax Court of New Jersey ruled in Preserve II, Inc. v. Division of Taxation that a limited partner’s interest in a partnership doing business in New Jersey created nexus for corporation...more

Framework for Tax Reform Released

by Williams Mullen on

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released a unified framework (the Framework) with the stated goal of achieving pro-American,...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

by King & Spalding on

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

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