THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more
A federal tax issue frequently arises when key employees of an operating business are given the opportunity to become equity holders. Despite the well-established rule that partners of a partnership are not permitted to be...more
On May 5, 2016, the Department of Treasury and the Internal Revenue Service published final and temporary regulations amending Treasury Regulations ยง301.7701-2 under Section 7701 of the Internal Revenue Code of 1986, as...more