Collaborating Before The PTAB
There are tax advantages for U.S. taxpayers to jointly develop intangible personal property with related non-U.S. entities.
Treasury Regulations provide detailed guidance on what costs must be shared between the...more
As employers and plans prepare for 2016 open enrollment, they must be sure to address in their benefit design and with their third party vendors the new embedded out-of-pocket maximum limitations on individuals that were...more
The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises.
Editor's Overview -
In this month's Newsletter, Robert Rachal discusses recent "church plan" rulings where some federal judges have declined to give deference to long-standing, consistent guidance from the Internal...more
IRS Notice 2013-54 provides that an employer’s reimbursement of healthcare insurance premiums paid by an employee on an individual health insurance contract of the employee on a pre-tax basis (an “employer payment plan”) may...more
The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax consequences.
Sometimes the business and/or financial assumptions around the planning...more
On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...more
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