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Searching Content indexed under Income Tax by Richard M Corn ordered by Published Date Descending.
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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
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
7
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
8
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
9
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
10
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
11
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
12
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
13
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
14
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
15
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
16
Federal Appellate Court Rules That Certain Foreign Currency Options Are Subject To The Section 1256 Mark-To-Market Regime
Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options.
United States
9 Feb 2016
17
Significant Changes To U.S. Taxation Of REITs And Investments By Non-U.S. Investors In Real Property Under The PATH Act
On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015.
United States
3 Feb 2016
18
Proposed Treasury Regulations Aim To Curb Elective Treatment Of M&A Transaction Costs
Some taxpayers have taken the position that an acquiring corporation and a target corporation, when the target corporation is joining the acquiring corporation's consolidated corporate group, can choose between taking certain acquisition-related expenses into account in the target's pre-acquisition taxable year or the post-acquisition consolidated taxable year.
United States
1 Apr 2015
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