Mondaq USA: Tax
Proskauer Rose LLP
First, the proposed regulations clarify the "device" test and its relationship to the "business purpose" requirement.
Dentons
The IRS and Petitioners had agreed that Petitioners would run a search for terms determined by the IRS on the potentially relevant documents.
Foley & Lardner
The IRS just published long-awaited temporary regulations under section 1.50-1T governing the section 50(d)(5) income inclusion rules.
Reed Smith
The Multistate Tax Commission ("MTC") held its Annual Commission Meeting today. Of note, the MTC voted to adopt the Model Sales and Use Tax Nexus Statute. In addition, the Arm's-Length Adjustment Service Committee ("ALAS") met and reported on the status of its transfer-pricing project.
McDermott Will & Emery
New Internal Revenue Service temporary regulations provide guidance on the income inclusion rules that apply when a lessor elects to treat a lessee as having acquired investment credit property under Treas. Reg. § 1.48-4.
Shearman & Sterling LLP
One of the requirements for a tax-free spin-off under Section 355 is that the distributing corporation ("D") distributes stock of the controlled corporation ("C") representing "control" of C (the "Distribution of Control Requirement").
MSPC
Most tax-exempt organizations other than churches and certain church-related organizations are required to file an annual information return or notice (Form 990, 990-EZ, 990-PF, or 990-N (e-Postcard)) with the IRS.
MSPC
The Patient Protection and Affordable Care Act of 2010 (the "ACA") imposes significant information reporting responsibilities on certain employers starting with the 2015 calendar year.
Strasburger & Price, L.L.P.
Every holiday season, I, like many other Americans, watch Frank Capra's classic, It's a Wonderful Life.
Strasburger & Price, L.L.P.
Under the BBA rules, if a partnership understates its income or overstates its deductions, it is subject to an income tax.
Stoll Keenon Ogden PLLC
David O'Neill sent a letter to the Kentucky Department of Revenue seeking advice on the meaning and application of the statutory requirements for valuing agricultural property...
Grant Thornton LLP
President Obama has signed a bill reauthorizing the Federal Aviation Administration (FAA) and extending aviation taxes for 15 months.
Grant Thornton LLP
Section 61 generally states that gross income includes all income from all sources, but Section 118(a) provides an exception for contributions to the capital of a corporation.
McDermott Will & Emery
Taxpayers value confidentiality, particularly if there is a dispute with the IRS that involves highly-sensitive trade secrets or other confidential information.
Duane Morris LLP
Employers use this form to determine how much federal income tax to withhold from your pay.
Baker Newman Noyes
Last summer, we provided an update from the IRS clarifying that it now believed 220,000 records were compromised, and 390,000 total attempts were made.
McDermott Will & Emery
On July 13, 14, and 15, 2016, Judge Laro of the US Tax Court (Tax Court) ruled on five taxpayer-filed motions in limine to exclude expert reports in Guidant LLC f.k.a. Guidant Corporation, and Subsidiaries, et al. v. Commissioner.
Cadwalader, Wickersham & Taft LLP
At a public hearing, the Internal Revenue Service and the U.S. Treasury Department examined proposed regulations under Section 385 of the Internal Revenue Code.
Grant Thornton LLP
The IRS has issued final regulations for determining whether disregarded entities can be considered the "taxpayer" for the bankruptcy and insolvency exceptions to cancellation of debt income rules.
Grant Thornton LLP
The IRS has issued final regulations under Section 446 (T.D. 9774) that provide a simplified method of accounting for gains and losses on shares in a money market fund (MMF).
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Grant Thornton LLP
The IRS provided guidance in Notice 2016-39 on whether payments an employee receives from a qualified defined benefit plan during phased retirement are amounts received as an annuity under Section 72.
Holland & Knight
The IRS has published its long-awaited proposed rules on nonqualified deferred compensation plans under Section 409A of the Internal Revenue Code of 1986, as amended (Section 409A).
Kaye Scholer LLP
G20 finance ministers last week finally approved the wide-ranging "BEPS" reforms to the international tax system.
McDermott Will & Emery
Late last year, the Internal Revenue Service's (IRS's) Large Business and International (LB&I) division announced that it would restructure its organization.
Foley Hoag LLP
In each of these cases, a pre-existing account will not become subject to FATCA until its value exceeds $1 million on a subsequent December 31st.
Shearman & Sterling LLP
On June 26, 2016, a widened Panama Canal will open for business after a ten-year, USD5.3bn expansion project is completed.
Dentons
A recent summons showdown with UBS shows that DOJ and the IRS are far from done with offshore enforcement efforts, and are expanding those efforts beyond Europe.
Thompson Coburn LLP
Virtually all official rules for sweepstakes or contests in the United States include the Approximate Retail Value (ARV) of each prize.
Brown Smith Wallace
A taxpayer changing its method of accounting must either request advance IRS consent or apply for automatic IRS consent on Form 3115, Application for Change in Accounting Method, to make the change.
McDermott Will & Emery
On June 21, 2016 the IRS issued proposed regulations to modify and clarify existing regulations under Section 409A of the Internal Revenue Code.
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