News & Analysis as of

Distribution Rules Income Taxes

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part IX – Taking the...

Foster Garvey PC on

Unlike the rules contained in Subchapter K surrounding partnership distributions, which tend to be somewhat complex, the distribution rules contained in Subchapter S are fairly straightforward. Nevertheless, from time to...more

Freeman Law

Tax Court in Brief | Lucas v. Comm’r | Deficiency for Early 401(k) Distribution; 10% Additional Tax; Exclusion for “Unable to...

Freeman Law on

Summary: In 2017, Robert Lucas worked as a software developer, but he lost his job in that year. To make ends meet, he obtained a distribution of $19,365 from a section 401(k) plan. He had not reached 59 1/2 years old at the...more

International Lawyers Network

Establishing A Business Entity In Denmark (Updated)

1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more

Gray Reed

A Horse, a Horse, My Kingdom for a Horse! Lack of Proper Documentation Dooms IRS Disputes

Gray Reed on

In real life (and especially, it seems, in tax law) it is more like to be the lack of a timely piece of paper that causes the taxpayer to lose. In the course of administering a trust, it sometimes happens that mistakes...more

International Lawyers Network

Establishing A Business Entity In Denmark (Updated)

1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more

Sullivan & Worcester

Mid-Year Retirement Benefits Update

Sullivan & Worcester on

The Internal Revenue Service has been busy issuing guidance over the last month or so on various retirement benefit issues. We want to be sure you are aware of these important updates. Retirement plan and IRA liquidity...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS Released COVID Distribution Q&A

The Internal Revenue Service (IRS)N has issued a series of an FAQ questions and answers regarding the CARES Act coronavirus-related relief for retirement plans. The coronavirus-related distribution and loan rules generally...more

Holland & Knight LLP

Tax Court Upholds Application of Subpart F Manufacturing Branch Rule

Holland & Knight LLP on

A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner - March/April 2020

Creating an education legacy - For many people, an important goal of estate planning is to leave a legacy for their children, grandchildren and future generations. And what better way to do that than to help provide for...more

International Lawyers Network

Establishing A Business Entity In Denmark (Updated)

1. TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

IRS offers guidance on uncashed checks, but not really

In a recent revenue ruling, the IRS stated that if a participant or a beneficiary doesn’t cash a distribution check in the year it was issued, the individual still must include the amount in gross income for that year....more

Lowndes

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

Lowndes on

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Lowndes

The End of Leveraged Partnership Transactions?

Lowndes on

If a partner contributes property to a partnership, and within a two year period, receives cash from that partnership, the tax rules generally treat that as a disguised sale of property by the partner to the partnership. ...more

Seyfarth Shaw LLP

IRS Allows Self-Certification For Waiver of 60-Day Rollover Requirement

Seyfarth Shaw LLP on

On August 24th, the IRS released guidance that permits an automatic waiver of the sixty-day rollover period for retirement plan distributions by allowing individuals to self-certify that they qualify for the waiver under any...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Guide to the UK Disguised Investment Management Fee Rules

New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more

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