BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Correcting Problems With Your Retirement Plan
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
Did the IRS Just Help or Hurt the Bitcoin Economy?
Tax Traps of Employment Documents
BB&K's Isabel Safie Discusses the Implications of IRS’ Definition of Governmental Plan Status
Fantasy Football: The Legal Reality
Hot Topics for Waste-to-Energy Investors and Developers
In T.D. 9728 the IRS finalized the 2009 proposed § 706(d) regulations relating to how partnerships should allocate tax items to take into account a variance in a partner’s interest during a year. A typical example is when a...more
Effective January 1, 2017, the IRS has announced that, due to limited resources, it is eliminating the existing 5-year determination letter application staggered filing cycles for individually designed plans. Off-cycle...more
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into...more
Overview. Many sophisticated estate planning techniques include gifts, sales or other transfers to family members that incorporate significant discounts on the value of the property transferred. These discounts can range from...more
The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more
On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more
The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more
On Wednesday July 22, 2015, the Internal Revenue Service (“IRS”) issued Proposed Regulations (REG-115452-14) providing guidance to partnerships and partners as to whether an arrangement between a partnership and a service...more
It may not be at the forefront of your digital currency interests, but cryptocurrencies have unique characteristics that require careful consideration for estate planning.
If you have bitcoin, for example, but your...more
On July 21, 2015, the Internal Revenue Service (“IRS”) released Announcement 2015-19, which significantly limits the circumstances under which the IRS will accept determination letter applications for individually designed...more
On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more
On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more
On July 22, 2015, the Treasury Department and the IRS published proposed regulations (the "Proposed Regulations") that address the circumstances in which allocations or distributions made by a partnership to a partner that...more
CMS offers a special enrollment period for HealthCare.gov enrollees whose incomes were miscalculated due to system error; California Marketplace announces two new insurers; and Connecticut’s budget reduces eligibility levels...more
On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more
Since its founding in 2009, Uber has gained both praise and notoriety for shaking up the taxi industry by allowing individuals who meet minimum requirements to provide an on-demand car service via the Uber mobile app. In...more
After stepping down from running the family oil business (see last month’s article), Jed Clampett runs Mama’s Fried Pies, his late wife Rose Ellen’s fried pie business. With business booming, Jed decides to hire Elly May as...more
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
Editor's Overview -
This month's article by Lindsey Chopin discusses Affordable Care Act ("ACA") litigation. Just five years old, the Supreme Court has considered issues related to the ACA numerous times. Two of those...more
With the impending deadline early next year, most applicable large employers are (or should be) in the process of gearing up for what is perhaps the biggest Affordable Care Act (“ACA”) compliance challenge this year — the...more
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
A representative from the Internal Revenue Service (IRS) recently signaled that new rules are expected to be released that could significantly impact taxpayers' ability to claim discounts on gifts of interests in...more
This Week: CMS Releases Guidance on Fast Track Process for 1115 Waivers for Medicaid and CHIP... Healthcare.gov CEO Sends Letter to State Insurance Commissioners Concerning 2016 Premium Decisions... Medicare Board of Trustees...more
Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more
The IRS has announced significant changes to its qualified plan determination letter program. These changes, which become effective January 1, 2017, impact individually-designed plans.
Favorable determination letters...more
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