Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more
11/3/2017
/ 501(c)(3) ,
Alternative Minimum Tax ,
Charitable Deductions ,
Child Tax Credit ,
Corporate Taxes ,
Deduction Limitations ,
EBITDA ,
Educational Institutions ,
Estate Tax ,
FDAP ,
Foreign Corporations ,
Foreign Subsidiaries ,
Fringe Benefits ,
International Tax Issues ,
Like Kind Exchanges ,
Meal and Entertainment Expenditures ,
Medical Expenses ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Pass-Through Entities ,
PFIC ,
Private Foundations ,
Property Tax ,
Proposed Legislation ,
Religious Institutions ,
Retirement Plan ,
Roth IRA ,
Section 179 Property ,
Section 409A ,
Section 457A ,
Section 501 ,
Shareholders ,
Tax Cuts ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds
In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more
10/18/2017
/ Applicability Date ,
Extraordinary Circumstances Exception ,
IRS ,
NPRM ,
Partnerships ,
Private Letter Rulings ,
Proposed Regulation ,
Regulatory Burden ,
Regulatory Reform ,
Tax Reform ,
U.S. Treasury ,
User Fees
Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions. The Journal article notes that the S&P Spin-Off Index has outperformed the S&P 500...more
On September 21, 2017, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2017-52 (the “Rev. Proc.”), introducing an 18-month “pilot program” in respect of corporate “spin-off,” “split-up” and “split-off”...more
9/25/2017
/ Capital Gains ,
Corporate Taxes ,
Distribution Rules ,
Federal Pilot Programs ,
IRS ,
Parent Corporation ,
Public Comment ,
Section 355 ,
Shareholders ,
Spinoffs ,
Subsidiaries ,
Tax-Free Spin-Offs
On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not give rise to a taxable exchange to the obligor because a VPFC is solely an...more
Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more
On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more
The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more
1/20/2017
/ Business Ownership ,
C-Corporation ,
Final Rules ,
Foreign Corporations ,
IRS ,
Passive Foreign Investment Company ,
PFIC ,
Reporting Requirements ,
S-Corporation ,
Stocks ,
U.S. Treasury
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more
In the U.S. general election held on November 8, 2016, Donald J. Trump was elected to become the 45th President of the United States. Republicans also retained their majorities in both the U.S. House of Representatives and...more
11/11/2016
/ Alternative Minimum Tax ,
Business Taxes ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Net Operating Losses ,
Presidential Elections ,
Presidential Nominations ,
Research and Development ,
Tax Credits ,
Tax Deductions ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
Trump Administration
The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once again to seek private letter rulings on issues of “corporate business...more
On July 15, 2016, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations that would modify the device and active trade or business requirements for tax-free...more
7/29/2016
/ Active Trade or Business Test ,
Device Test ,
Grandfathering Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Section 355 ,
Shareholders ,
Spinoffs ,
Tax Avoidance ,
Tax-Free Transfers ,
U.S. Treasury ,
Yahoo!
On December 21st, 2015 the IRS proposed Country-by-Country (“CbC”) reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations (including their revenue, number of...more
The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S....more
Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more
On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015 (the "Act"). In addition to extending or making permanent a number of...more
The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more
Some taxpayers have taken the position that an acquiring corporation and a target corporation, when the target corporation is joining the acquiring corporation's consolidated corporate group, can choose between taking certain...more
We last updated our clients and friends in February 2014 (Feb 2014 Memorandum) on issues related to the disclosure and automatic exchange of financial information on an international basis.
Since then, the pressure...more
One might have thought the biggest news in the digital currency world lately was Dell announcing that it was now accepting bitcoin. However, after a series of highly-publicized hearings in January, New York State rolled out...more