The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
A new program offers rulings in 12 weeks, even absent a showing of business need.
Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
8/3/2023
/ Annual Filings ,
Corporate Taxes ,
Fast Track Process ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Revenue Procedures ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently.
What Is (and Is Not) Covered?
The three-year restriction applies with respect to...more
9/1/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
11/7/2017
/ Acquisitions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Death Tax ,
EBITDA ,
Excise Tax ,
Executive Compensation ,
Foreign Corporations ,
Foreign Earned Income ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Itemized Deductions ,
MACRS ,
Mortgage Interest ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Principal Executive Officer ,
Proposed Legislation ,
REIT ,
Section 409A ,
Shareholders ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Transfer Taxes ,
Trump Administration ,
Ways and Means Committee
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
10/11/2017
/ Alternative Minimum Tax ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Family Businesses ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
Multinationals ,
Pass-Through Entities ,
Proposed Legislation ,
Repatriation ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more