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1
Transfers Of Securities Result In No Loss, IRS Says In Technical Advice
The IRS concluded in a technical advice memorandum (TAM 201737011), released on Sept. 15, 2017, that transfers of stock did not result in losses recognized by the respective taxpayers.
United States
5 Oct 2017
2
Notice Modifies The Application Of Section 367 To Certain Triangular Reorganizations And Inbound Transactions
The IRS on Dec. 2 issued Notice 2016-73 announcing that the government intends to issue regulations under Section 367 modifying the rules relating to the treatment of property used to acquire parent stock...
United States
21 Dec 2016
3
Treasury Issues Proposed Regulations Addressing Two Aspects Of RIC Qualification
The Treasury Department and the IRS recently issued proposed regulations (REG-123600-16) that provide guidance on the requirements a corporation must satisfy to qualify as a regulated investment company.
United States
18 Oct 2016
4
IRS Issues Final Regs On Money Market Funds
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).
United States
22 Jul 2016
5
IRS: Certain Disgorgement Payments Not Deductible
The IRS Office of Chief Counsel issued a chief counsel advice (CCA) memorandum (CCA 201619008) to the Large Business and International Division regarding the deductibility of certain disgorgement payments.
United States
24 May 2016
6
Treasury Issues Proposed Regulations On Deemed Distributions Of Stock
Treasury and the IRS issued proposed regulations (REG-133673-15) related to distributions of a corporation's stock under Section 305.
United States
5 May 2016
7
South Carolina Supreme Court Rejects Duke Energy's $126 Million
Duke Energy generates and sells electricity in South Carolina and other states. As a result, it must apportion its income to determine the income attributable to, and taxable in, South Carolina.
United States
14 Apr 2016
8
Highlights Of The 2015 AICPA Conference On Current SEC And PCAOB Developments
The 2015 AICPA Conference on Current SEC and PCAOB Developments, held in Washington, D.C., December 9–11, featured representatives from the SEC, PCAOB, FASB, IASB, and AICPA...
United States
10 Feb 2016
9
S Corporation Cannot Take An Ordinary Worthless Stock Deduction
In general, Section 165(g)(1) provides for the recognition of a capital loss for any security that is a capital asset that becomes worthless.
United States
5 Feb 2016
10
IRS Rules On Implications For The Active Trade Or Business Requirements Of Section 355
The IRS recently ruled in a private letter ruling (PLR 201551009) on the implications of gain recognition under Section 751 in the context of a Section 355 spinoff.
United States
5 Feb 2016
11
IRS: Indemnity Obligations Are Not Securities Subject To Mark-To-Market
The IRS concluded in a chief counsel advice (CCA) memorandum that indemnification obligations related to originated mortgages did not constitute a security subject to Section 475.
United States
20 Aug 2015
12
IRS Defers Applicability Of Broker Reporting Rule
The IRS issued amendments (T.D. 9713) to the regulations under Section 6045A to delay until 2016 the new broker basis and premium reporting requirements that apply to transfers of debt instruments.
United States
25 Jun 2015
13
Corporate Transactions And Operations
Fifth Circuit holds that abandonment of securities is ordinary loss.
United States
18 Mar 2015
14
IRS Supplements Prior Spinoff Ruling Following Taxpayer Delay
In a private letter ruling (PLR 201505013), the IRS supplemented its previous ruling in PLR 201437013 and addressed issues related to a delay in the expected consummation of a spinoff.
United States
5 Mar 2015
15
Nonrecourse Debt Affects Mark-To-Market Calculation
The IRS concluded in an internal legal memorandum released Feb. 13 that a taxpayer’s nonrecourse liability affected its mark-to-market computation under Section 475(a).
United States
4 Mar 2015
16
In Considering Single, Discrete Issue, IRS Rules On Distributing Corporation’s Retention Of Stock In Spin-Off
In a private letter ruling released on Jan. 16 ( PLR 201503006), the IRS considered a single, discrete legal issue related to a proposed Section 355 spin-off transaction.
United States
4 Feb 2015
17
Highlights Of The 2014 AICPA Conference On Current SEC And PCAOB Developments
This publication provides an overview of key matters discussed during the conference.
United States
16 Jan 2015
18
IRS Concludes Partner Was Not A Dealer In Securities
The IRS concluded that a taxpayer’s status as a partner in a partnership that was a dealer in securities did not mean the taxpayer was a dealer in securities under Section 475(c).
United States
9 Jul 2014
19
Certain Litigation Costs Are Ordinary And Necessary Business Expenses, IRS Rules
In a private letter ruling (PLR 201412002), the IRS ruled that certain costs incurred by a corporate taxpayer to settle a lawsuit, including settlement payments and legal fees, were deductible as ordinary and necessary business expenses under Section 162.
United States
16 Apr 2014
20
IRS Releases Temporary And Proposed Regulations On Inversions
The IRS has issued temporary (T.D. 9654) and proposed (REG-121534-12) regulations providing guidance on the identification of certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation under the inversion rules of Section 7874.
United States
30 Jan 2014
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