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By Joanne Youn, Ronald Cluett
Nor does the legal analysis end once a plan has satisfied itself that the church plan exemption properly applies.
By Joanne Youn, Ronald Cluett
The OC List provided on the IRS website identifies changes in qualification requirements effective during a calendar year.
By Christopher Rizek, Charles Ruchelman, Rachel Partain, Arianna Caldwell
On November 1, 2016, the Internal Revenue Service ("IRS") issued Notice 2016-66, identifying certain transactions relating to "micro-captive" insurance companies as "transactions of interest."
By Trevor Potter, Matthew Sanderson, Bryson Morgan
This past weekend, President Donald Trump signed an Executive Order requiring all new appointees in his Administration to sign an ethics pledge that contains special "revolving door" and gift restrictions.
By Mark D. Allison, J. Clark Armitage, Kirsten Burmester, Niles Elber, Neal Kochman, Rachel Partain, Charles Ruchelman, James Salles, Zhanna Ziering, Dustin Barzell
On January 31, 2017, the Internal Revenue Service launched its first wave of compliance "campaigns." A campaign is an issue-based compliance process centering on focused examinations, staffed with IRS experts on the targeted subject matter.
By Jonathan Brenner, Mark D. Allison, Richard Skillman, Kirsten Burmester, Peter Barnes
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump's proposal and Speaker of the House Paul Ryan's proposal on key corporate tax provisions . . .
By Christopher Rizek, Charles Ruchelman, Arianna Caldwell
On December 23, 2016, the Internal Revenue Service ("IRS") issued Notice 2017-10 identifying certain transactions involving conservation easements as "listed transactions."
By Joanne Youn, Ronald Cluett
In Revenue Procedure 2016-37, the IRS formally announced the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed, qualified retirement plans.
By Kirsten Burmester, Scott D. Michel, J. Clark Armitage, Arianna Caldwell
The IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by obtaining a U.S. "TIN and in many circumstances, filing annual returns.
By Charles Ruchelman, Jonathan Brenner, Rachel Partain, Elizabeth Stevens
The Bipartisan Budget Act of 2015 fundamentally changed the rules by which partnerships, and entities taxed as partnerships, interact with the Internal Revenue Service in an audit or litigation.
By Beth Kaufman, Jonathan Brenner, Anne O’Brien
This alert summarizes current law, President-Elect Trump's proposal, and Speaker of the House Paul Ryan's proposal on key individual income tax provisions relevant to high-net-worth individuals.
By Beth Kaufman, Anne O’Brien, Megan Wernke, William Fournier
The election of Donald Trump as the next President, along with continued Republican party control of both the House and the Senate, could signal that 2017 will be the year that the estate tax is repealed.
By Scott D. Michel, Mark E. Matthews
On November 30, 2016, a federal court in San Francisco authorized the IRS to issue a "John Doe" summons to Coinbase, Inc., which operates a web-based global convertible digital currency wallet...
By Trevor Potter, Matthew Sanderson, Bryson Morgan
Effective January 1, 2017, the Office of Government Ethics (OGE) is revising the gift rules applicable to executive branch employees.
By Rachel Partain, Mark D. Allison, Christopher Rizek, Charles Ruchelman
Each of the insureds, captives, and any material advisors must report the transaction to the IRS, including the IRS Office of Tax Shelter Analysis.
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