Latest Publications

Share:

Congress Fixes “Grain Glitch” Error in 199A

On March 23, the Consolidated Appropriations Act (the “Appropriations Act”) was signed into law by President Trump. Included in the Appropriations Act were certain tax law provisions, including technical corrections to the...more

Partnership Audit Rules Clarified by the Consolidated Appropriations Act

Technical corrections to the partnership audit rules were included in the 2018 Consolidated Appropriations Act signed by President Trump on March 23rd (the “Appropriations Act”). ...more

U.S. Internal Revenue Service Cancels Offshore Amnesty Program

The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more

IRS Clarifies Deductibility of Home Equity Loan Interest Following the 2017 Tax Act

The IRS recently issued Notice 2018-32, which advises taxpayers on the ability to deduct interest on home equity loans (collectively, a “HELOC”) following the 2017 Tax Act. This is a timely response to the questions that...more

Treasury to Issue Carried Interest Regulations Closing Perceived S Corporation Loophole

The taxability of a “carried interest” has been subject to much debate. A “carried interest” is a term of art used to refer to the receipt of a profits interest, a popular structure in entities taxed as partnerships with...more

Proposed Section 2704 Regulations to be Withdrawn

Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more

Ole Miss Substantially Prevails in Tax Court Case over Taxability of Coach Appearances

Tax exempt organizations must report and pay tax on their “unrelated business income.” Butler Snow recently represented The University of Mississippi (“UM”) in a federal income tax dispute in the United States Tax Court...more

Is Tax Reform On the Horizon?

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

Owners of Family Controlled Entities Must Act Quickly in Light of New IRS Regulations Attacking Valuation Planning

Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools...more

Planning for the $5-$10 Million Couple: Portability or Credit Shelter?

In 2009, each individual had a $3.5 million estate tax exemption. If a married individual had assets over $3.5 million, without careful planning, those assets in excess of $3.5 million would fall subject to a 45% estate tax....more

Executors Responsible for New Estate Reporting Requirements

Executors (or beneficiaries in certain situations) of estates for which an estate tax return was required to be filed under Section 6018(a) after July 31, 2015 must now supply the IRS and each person acquiring any interest in...more

Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners

On Wednesday, 26 June 2013, the US Supreme Court ruled that Section 3 of the Defense of Marriage Act (“DOMA”), which limits the definition of “marriage” to “a legal union between one man and one woman as husband and wife” and...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

13 Results
/
View per page
Page: of 1

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.