News & Analysis as of

Internal Revenue Service Asset Transfer

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Strafford

[Webinar] New IRS Guidance on Basis Adjustments for Irrevocable Grantor Trusts: Key Issues for U.S. and Non-U.S. Persons - June...

Strafford on

This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more

Cadwalader, Wickersham & Taft LLP

New Proposed 'Killer B' Regulations Reduce Compliance Sting

On October 5, the U.S. Treasury released long-awaited proposed regulations regarding inbound cross-border reorganizations, implementing (with modifications) policies that had been announced in 2014 and 2016 notices. These...more

Paul Hastings LLP

Treasury and IRS Issue Long-Awaited Guidance on Energy Tax Credit Transfers

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more

BakerHostetler

Overview of the Proposed Regulations Addressing Transferring Renewable Credits

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more

Lathrop GPM

Valuable Lessons in Charitable Deductions

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A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. While generally donors who donate appreciated property to a public charity do not recognize...more

Holland & Knight LLP

IRS anuncia amnistía fiscal internacional nueva hasta el 30 de septiembre de 2022

Holland & Knight LLP on

El servicio de impuestos internos de Estados Unidos (Internal Revenue Service o IRS) recientemente anunció una amnistía nueva que permite presentar ciertas declaraciones de 2019 y 2020 sin multa antes del 30 de septiembre de...more

Stoel Rives LLP

Gift Planning in 2022

Stoel Rives LLP on

Each year, the IRS considers inflationary adjustments to the estate and gift tax exemption amount and gift tax annual exclusion amount. As you consider estate planning or making gifts during the new year, here are the numbers...more

Steptoe & Johnson PLLC

Selling Assets to Reduce Your Estate Tax Exposure - Act Before September 30

Steptoe & Johnson PLLC on

If you have an estate that may be subject to estate tax next year, particularly if the November election results in a greatly reduced federal estate tax exemption in 2021, now is the time to remove assets from your taxable...more

Manatt, Phelps & Phillips, LLP

Proposed 2704 Regulations Attack Valuation Discounts

The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...more

Perkins Coie

Don’t Burst My Bubble! IRS Provides Clarity for F Reorganizations

Perkins Coie on

Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

Orrick, Herrington & Sutcliffe LLP

IRS Announces Intent to Tax Transfers to Partnerships

On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more

Proskauer Rose LLP

Personal Planning Strategies - July 2015

Proskauer Rose LLP on

Income Tax Considerations of Estate Planning Are More Important Than Ever - Gifting assets during life will reduce the size of your taxable estate at death and, correspondingly, reduce your estate tax liability. But with...more

Bradley Arant Boult Cummings LLP

Charitable Lead Annuity Trusts: An Estate Planning Strategy for a Low-Interest-Rate Environment

In the current economic environment, IRS-prescribed monthly interest rates for certain intra-family transactions are at historic lows. As a result, an excellent opportunity exists to transfer wealth to lower generation family...more

McDermott Will & Emery

OECD/BEPS Intangibles Revisions to Change Character, Treatment of Goodwill

McDermott Will & Emery on

Corporations acquiring intangible assets as part of business combination will no longer be able ignore goodwill in their subsequent restructurings and asset transfers. That’s the upshot from tax authorities from around the...more

Eversheds Sutherland (US) LLP

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

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