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The IRS has stated that it is committed to finalizing these regulations by the end of the summer.
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In recently issued final and temporary regulations, the IRS has clarified the tax treatment of partners in a partnership that owns a disregarded entity for which the partners work as employees.
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When an employer pays an expense reimbursement or advance to an employee, the IRS considers the arrangement to be disguised taxable compensation to the employee.
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On May 5, 2016, the U.S. Treasury Department announced several actions intended to strengthen financial transparency, including the issuance of proposed regulations that significantly increase the reporting and record maintenance requirements of U.S. disregarded entities owned by foreign persons.
The IRS has released temporary and proposed regulations clarifying that partners in a partnership that owns a disregarded entity (DRE) may not be treated as "employees" of the DRE (T.D. 9766; REG-114307-15).
Foley & Lardner
In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes.
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In 2009, each individual had a $3.5 million estate tax exemption. If a married individual had assets over $3.5 million, without careful planning, those assets in excess of $3.5 million...
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Public comments on the proposed regulations may be submitted through August 8, 2016. If approved, the proposed regulations will become effective twelve months after they are published as final in the Federal Register.