New anti-abuse provisions
As discussed in prior articles, there are several options for tax-incentivized giving, ranging from the informal and low-involvement to complex and highly involved structures. Many choose to adopt a more formal approach to...more
Corporate entities under common control are generally treated as a single employer for purposes of applying the core rules that govern employee benefit plans and executive compensation arrangements. For that reason, a...more
On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more