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Corporate Taxes Internal Revenue Service Compliance

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Morgan Lewis

Large Corporate Compliance and Data Analytics: Have You Analyzed Your Own Data Recently?

Morgan Lewis on

The Internal Revenue Service will be implementing a new program using data analytics to select which large corporate taxpayers to audit. The program will identify which corporate tax returns show the highest compliance risk...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Goulston & Storrs PC

New Trade Act Hikes Penalties for Information Return Failures

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The newly-enacted Trade Preference Extension Act boosts the penalties for failing to provide accurate information returns to the IRS and payees – such as Forms W-2, 1098, and 1099, as well as Forms 1095-B and 1094-B. The...more

King & Spalding

IRS Clarifies "Substantial Risk of Forfeiture"

King & Spalding on

The Internal Revenue Service ("IRS") recently issued final regulations clarifying whether a substantial risk of forfeiture exists in connection with a transfer of property, such as restricted stock, in connection with the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Large Business and International Division Increasingly Looks to Chief Counsel's Office to Advance Initiatives"

The Internal Revenue Service Large Business and International Division (LB&I) administers United States tax law for corporations, partnerships and individuals with assets greater than $10 million. These taxpayers typically...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Releases Final and Proposed Regulations Regarding Dividend Equivalent Payments to Foreigners"

As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities...more

Orrick, Herrington & Sutcliffe LLP

Post-Issuance Tax Compliance and Continuing Disclosure Responsibilities for Issuers and Borrowers of Tax-Exempt Bonds

Chapter One: Introduction: Why Post-Issuance Compliance? Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators, including the Internal Revenue Service...more

Troutman Pepper

IRS Rules That A Partially Tax-Free Transaction Qualifies As ‘Covered Transaction’ For Purposes Of The Transaction Cost...

Troutman Pepper on

The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5....more

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