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Tax Reform Private Letter Rulings

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

DarrowEverett LLP on

Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

McDermott Will & Emery

Weekly IRS Roundup January 13 – 17, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more

King & Spalding

Compensation and Benefits Insights - September 2018

King & Spalding on

The IRS recently updated its two model safe harbor explanations that can be used to satisfy the requirement under Section 402(f) to provide notices setting forth certain information to participants who are eligible for...more

Proskauer - Tax Talks

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

Proskauer - Tax Talks

Tax Planning is Crucial to Achieve Potential Spin-Off Benefits

Proskauer - Tax Talks on

Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions. The Journal article notes that the S&P Spin-Off Index has outperformed the S&P 500...more

Mintz - Public Finance Viewpoints

Tax Guidance to Slow Under Trump. Even More Emphasis on Letter Rulings in Bond Transactions?

As the Trump administration attempts to substantially reduce the amount of federal regulations, both the Deputy Tax Legislative Counsel of the Treasury Department and an Associate Chief Counsel at the Internal Revenue Service...more

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