In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more
IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court -
In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more
12/16/2015
/ Administrative Appeals ,
Attorney-Client Privilege ,
Estate Tax ,
Good Faith ,
Income Taxes ,
Insurance Contracts ,
IRS ,
Multistate Tax Compact ,
Retroactivity ,
Tax Court ,
Tax Litigation ,
Tax Shelters ,
WA Supreme Court
Regulatory Developments Under ยง 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury