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Searching Content by Richard M Corn from Proskauer Rose LLP ordered by Published Date Descending.
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1
Proposed Regulations On Built-In Gains And Losses Under Section 382(h)
On September 10, 2019, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury (the "Treasury")
United States
25 Sep 2019
2
State Tax On Trust Income Based Solely On In-State Residence Of Beneficiaries Found Unconstitutional
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, "Kaestner").
United States
11 Jul 2019
3
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
4
Players, Staff And Draft Picks May Be Traded Tax-Free Under New Safe Harbor
On April 11, 2019, the Internal Revenue Service (the "IRS") issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts
United States
14 May 2019
5
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
6
Parsonage Exclusion Found By Seventh Circuit To Be Constitutional
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
United States
17 Apr 2019
7
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
8
Proposed Rental Business Safe Harbor Under Section 199A
On January 18, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury issued final regulations on the "pass through" deduction under section 199A[1] of the Internal Revenue Code (the "Code").
United States
13 Feb 2019
9
Treasury And IRS Issue Proposed "Pass-Through Deduction" Regulations
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction"
United States
31 Aug 2018
10
Digital Economy: Supreme Court Overturns Physical Presence Requirement For State Sales Tax
In a landmark decision changing course on decades of precedent, the United States Supreme Court decided on June 21, 2018 South Dakota v. Wayfair, Inc., et al.
United States
3 Jul 2018
11
Impact of Recent Tax Legislation On M&A Transactions
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the "Tax Act") that may affect M&A Transactions.
United States
12 Feb 2018
12
House Of Representatives And Senate Conferees Reach Agreement On The Tax Cuts And Jobs Act (H.R. 1): Description Of The Conference Agreement And Differences From House And Senate Versions
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1), and released legislative text, an explanation...
United States
19 Dec 2017
13
U.S. Senate Passes Its Version Of The Tax Cuts And Jobs Act (H.R. 1); Descriptions Of The Bills Passed In The House And Senate And Outstanding Differences To Be Resolved In Conference
The final Senate bill, although similar to the bill passed by the Senate Finance Committee on November 16, contains several important changes.
United States
11 Dec 2017
14
House Of Representatives Passes The Tax Cuts And Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison Of The Bill Passed By The House And The Modified Senate Bill
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
United States
21 Nov 2017
15
The Senate Finance Committee's Proposal For Tax Reform, And How It Compares With The Bill Passed By The House Committee On Ways & Means
The provisions discussed are generally proposed to apply to tax years beginning after December 31, 2017, subject to certain exceptions.
United States
15 Nov 2017
16
IRS Issues Guidance On "North-South" Transactions
The Ruling, under the facts set forth under Situation 1, spells out the paradigmatic case of a "north-south" transaction.
United States
17 May 2017
17
Tax Court Rules That Extensions Of Variable Prepaid Forward Contracts Do Not Result In Taxable Exchanges
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical VPFC did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation...
United States
2 May 2017
18
Trump Administration Announces Outline of Its Tax Proposal
Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump's original tax reform proposal announced during the campaign and of the House Republicans' tax reform proposal (which is sometimes referred to as the "Blueprint").
United States
27 Apr 2017
19
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
20
IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385
On October 13, 2016, the Treasury Department and the Internal Revenue Service (IRS) issued final and temporary regulations under section 385 of the Internal Revenue Code.
United States
27 Oct 2016
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