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Net Investment Income Internal Revenue Service Safe Harbors

Carlton Fields

The Practical Need for Managers of Micro Captives and the Allure of 'Off Label' Uses

Carlton Fields on

Every tax season, the Internal Revenue Service releases a “Dirty Dozen” list of schemes that it considers abusive and widespread enough to present a systemic threat to its enforcement of the tax laws. This year’s list...more

Burr & Forman

IRS Changes Course And Provides Safe Harbor For "Real Estate Professionals" In Net Investment Tax Final Regulations

Burr & Forman on

Section 1411 of the Patient Protection and Affordable Care Act (the "ACA") levies a new 3.8% tax on "net investment income" (the "NII Tax"). Among other things, the net investment income subject to the NII Tax includes...more

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