On August 2024, the IRS, for the third time in two years, reminded taxpayers that crowdfunding monies may be taxable. Due to the popularity of crowdfunding monies raised online, the IRS issued News regarding how money raised...more
This CLE/CPE webinar will provide estate planners insight on recently issued IRS guidance regarding basis adjustments for irrevocable grantor trusts. The panelist will discuss key items and challenges stemming from Revenue...more
It is not uncommon, in the context of a business entity in which a family owns a controlling or substantial interest, for an adviser to encounter intersecting gift and income tax issues. This week’s post will consider one...more
Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more
The US Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) recently published proposed regulations under Section 4966 to provide additional guidance on several issues related to creating and...more
Summary: In this opinion, the Tax Court considered whether a deficiency was appropriate for Tony and Barbara Patrinicola’s 2016 tax year. The IRS determined that they had received unreported taxable pension distributions of...more
IRS may contact the recipients of crowdfunding campaign proceeds if not reported. IRS issues a soft alert to Taxpayers regarding their tax obligations for monies received under crowdfunding activities as well as the benefits...more
The Calm Before? I’m confused. For better or worse, I’m pretty sure that I am not alone. Last week, in a letter addressed to the American people, forty-six of the fifty Republicans in the U.S. Senate indicated they...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...more
New guidance from the Internal Revenue Service will allows RICs and REITs to retain more capital by distributing less cash to shareholders in certain stock distributions—welcome relief during the current economic volatility...more
The IRS recently issued guidance on the tax treatment, withholding and reporting for required distributions from tax-qualified retirement plans. Plan sponsors should contact their retirement vendors and trustees to ensure...more
Here are ten common questions I receive from clients about issuing equity (stock or options) to service providers (advisors/directors/officers/employees/consultants)...more
In Rev. Rul. 2019-19, which was issued on August 14, the Internal Revenue Service (IRS) took another small step in its undertaking to address tax issues raised by missing or unresponsive retirement plan participants. The...more
The Tax Cuts and Jobs Act of 2017 (“2017 Tax Act”) includes a provision that changed the rollover rules for certain plan loan offset distributions and that may not be well known to retirement plan sponsors and participants. ...more
• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
Section 19(a) of the Investment Company Act of 1940 (the 1940 Act) generally prohibits a business development company (BDC) or a registered investment company from making a distribution from any source other than its net...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
July Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-family Loans and Split Interest Charitable Trusts (Rev. Rul. 2018-16) - The July § 7520 rate for use with estate planning techniques such as CRTs,...more
I previously blogged about how unusual it was for the IRS to implement a retroactive change to a previously announced limit. As you may remember, the $6,900 limit on HSA contributions for a taxpayer eligible for a family high...more
To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns. Taxpayers want to make sure that their returns are processed correctly by the IRS. ...more
• President Donald Trump on Dec. 22, 2017, signed the Tax Cuts and Jobs Act, the first major overhaul of the U.S. tax system in over 30 years. • Although few of the enacted provisions are specific to Indian Country, several...more
If Congress is successful in lowering tax rates for at least some taxpayers in 2018, there are several year-end taxing-saving tips to consider prior to December 31st....more
GICs in India are evolving from cost-saving platforms into Innovation Centers for emerging digital technologies that can provide a competitive advantage. Recent years have seen a resurgence of interest in GICs in India...more