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Retroactive Taxes Internal Revenue Service

Fox Rothschild LLP

IRS is coming for NIL collectives

Fox Rothschild LLP on

It is a truism that agencies required to publicly release documents sometimes hold off on releasing those documents until a Friday afternoon, in the hopes it will be overlooked. The IRS lived up to that truism in releasing a...more

Jones Day

Warning: U.S. Tax Regulations Impact Completed Foreign Sales Retroactively and Domestic Partnerships

Jones Day on

The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Butler Snow LLP

Way, Way Back: Retroactivity in the Proposed 2801 Regulations

Butler Snow LLP on

Individuals who relinquished U.S. citizenship since 2008 may find themselves with U.S. tax exposure for gifts they made before they expatriated under proposed regulations announced by the IRS. Under the current expatriation...more

McDermott Will & Emery

Statute of Limitation: Congress Overrules Home Concrete and Retroactively Removes Some Taxpayer Defenses

McDermott Will & Emery on

On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law. In addition to extending various...more

Jackson Walker

Davidson v. Henkel — What’s Going On With Nonqualified Deferred Compensation Plans and FICA

Jackson Walker on

In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more

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