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Control Test Proposed Regulation

Holland & Knight LLP

The Corporate Transparency Act: An Update

Holland & Knight LLP on

The Corporate Transparency Act (CTA) will be effective on Jan. 1, 2024. For the first time, the United States now will require certain legal entities to report to the federal government identifying information about the...more

Troutman Pepper

Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation

Troutman Pepper on

On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Tax-Free Spin-Off Regulations Interpreting the "Device" and "Active Business" Tests and Addresses Recapitalizations...

On July 14, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 355 of the Internal Revenue Code that would establish new guidelines under the so-called "device" and "active business" tests....more

Butler Snow LLP

IRS Releases Proposed Regulations Defining a “Political Subdivision” For Purposes of Determining Eligibility to Issue Tax-Exempt...

Butler Snow LLP on

On February 22, 2016, the Internal Revenue Service (the “IRS”) released proposed treasury regulations (the “Proposed Regulations” ) to provide guidance as to how the IRS intends to prospectively define a “political...more

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