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Internal Revenue Service Alters Its View on Section 355 Spin-Offs

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

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

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

New Immediate Expensing Regulations Present Opportunities and Questions - Following up on 2018 proposed regulations, the...

The Treasury Department and Internal Revenue Service have issued final and proposed regulations (collectively, the new regulations) under section 168(k) of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and...more

Favorable Net Operating Loss Utilization Rules Could be Eliminated

Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership. On September...more

IRS Opens Pilot Program on Tax-free Spin-offs

The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more

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