Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
The Internal Revenue Service (IRS) has announced plans to initiate dozens of new audits this spring in an attempt to limit personal usage of corporate aircraft. These audits will focus primarily on “highest risk” corporations...more
Loans under the Payroll Protection Program (PPP) are eligible for forgiveness depending upon whether and when the loan proceeds are used for qualified business expenses. One of the benefits of this program is that there is no...more
A bill titled Jumpstarting Our Businesses’ Success Credit Act of 2020, which would make significant changes to the employee retention tax credits available under the CARES Act, is currently under consideration in the US House...more
As an update on an important matter that we raised during McDermott’s May 8 Tax Symposium, it is critical to promptly assess whether to report any excise taxes imposed under Section 4960 as the deadline for filing Form 4720...more
5/14/2019
/ Charitable Organizations ,
Employee Definition ,
Excise Tax ,
Filing Deadlines ,
Good Faith ,
Highly Compensated Employees ,
Internal Revenue Code (IRC) ,
IRS ,
Private Foundations ,
Privately Held Corporations ,
Proposed Regulation ,
Tax Exempt Entities ,
Volunteers
One of the more controversial and complex provisions of the Tax Cuts and Jobs Act has been the 21 percent excise tax on certain nonprofit executive compensation. On December 31, 2018, the IRS issued interim guidance that...more
On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code. Overall, Notice 2018-68 strictly interprets the Section 162(m) grandfathering rule under the...more
In early 2017, the IRS updated its Golden Parachute Payments Audit Technique Guide for the first time since its 2005 issuance. While intended as an internal reference for IRS agents conducting golden parachute examinations,...more
At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on “Maintaining Retirement Plan Documents after Revenue Procedure 2016-37.”
As an employer sponsoring a retirement plan, you are required by...more
On June 22, 2016, the Internal Revenue Service (IRS) issued proposed changes to the regulations under the Internal Revenue Code (Code) §409A. The Code intends to clarify or modify a wide range of very restrictive rules...more
8/9/2016
/ Corrections ,
Death Benefits ,
Deferred Compensation ,
Exemptions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Safe Harbors ,
Section 409A ,
Stock Options ,
Stocks ,
Termination
In Depth -
On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017,...more
In Depth -
Additional flexibility to use Section 409A exemptions -
..Expanded availability of the rules for transaction-based compensation for stock rights and incentive stock options. The final regulations allow...more
6/24/2016
/ Beneficiaries ,
Debt Collection ,
Deferred Compensation ,
Employee Benefits ,
Employee Stock Purchase Plans ,
Employee Stock Purchase Rights ,
Employment Contract ,
Hiring & Firing ,
IRS ,
Safe Harbors ,
Section 409A ,
Severance Pay
On June 21, the IRS issued long awaited proposed regulations under Section 457 of the Internal Revenue Code that affect a broad range of compensation arrangements at tax exempt organizations. If a compensation arrangement is...more
6/23/2016
/ Compensation Agreements ,
Deferred Compensation ,
Employee Benefits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Compete Agreements ,
Severance Agreements ,
Severance Pay ,
Tax Exempt Entities ,
Taxable Income ,
Vesting
Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more
Section 457A of the Internal Revenue Code (the Code) generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S....more
On February 26, 2014, U.S. House of Representatives Committee on Ways and Means Chairman Dave Camp (R-MI) released the proposed Tax Reform Act of 2014 (the Camp Proposal), which would simplify the Internal Revenue Code and...more
The Internal Revenue Service (IRS) recently released new final regulations under Section 83 of the Internal Revenue Code (the Code) that confirm several positions that it has successfully taken in litigation about what is ...more
The Internal Revenue Service recently published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately. FATCA imposes significant reporting obligations on both non-U.S....more