3,726 results found

Recently, the Internal Revenue Service ("IRS") announced an initiative to monitor tax-exempt health care organizations to ensure compliance with section 4958 of the Internal Revenue Code of 1986, as amended, regarding excess benefit transactions. Specifically, the IRS is looking at compensatory arrangements between a tax-exempt health care organization and a disqualified person to determine if an excess benefit transaction has occurred. A disqualified person includes any person in a position to

The final regulations provide for the treatment of an integrated transaction when the taxpayer disposes of or otherwise terminates all or a portion of the QDI or the hedge before maturity.

Treasury and the IRS intend to issue regulations addressing the application of Section 901(m) to disposition of assets following covered asset acquisitions.

The IRS issued Notice 2013-60, seeking to clarify prior guidance, Notice 2013-29, related to when a taxpayer has satisfied the requirements necessary to claim the renewable electricity production tax credit (PTC) under Section 45.

The IRS has issued guidance (Rev. Rul. 2012-19) on how dividends and dividend equivalents are treated for purposes of the $1 million compensation deduction limit under Section 162(m).

The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.

The IRS ruled in a chief council advice memorandum (CCA 2015-22-005) that a corporate officer of a common parent of a consolidated group must sign Form 2848...

The IRS has reversed its 2024 policy and will now issue private letter rulings on significant issues in corporate reorganizations and spin-offs, allowing taxpayers to request guidance on discrete legal matters rather than entire transaction structures.

The IRS has ruled in PLR 2013-06-004 that an S corporation's distribution agreement with its shareholders would not create a second class of stock under Section 1361(b)(1)(D).

The IRS said in a private letter ruling that a transfer of assets to a corporation by its sole shareholder constituted a transaction under Section 351, notwithstanding that the corporation would distribute assets to its shareholder prior to that contribution.

The Large Business & International division (LB&I) has issued a directive (LB&I-04-0814-007) to examiners that provides guidance in determining whether a taxpayer’s method for allocating mixed service costs (MSC) to certain self-constructed tangible personal property is appropriate and should not be challenged.

Five months after the Panama Papers leak of offshore client files, the ICIJ have released data from the corporate registry in the Bahamas pertaining to approximately 1.3 client million files.

As Cadwalader approaches its merger with Hogan Lovells on July 1, the firm reflects on eight years of BrassTax publication, which has provided clear insights on major tax developments from the 2017 Tax Cuts and Jobs Act to cryptocurrency taxation and energy tax credits. The publication will integrate into the combined firm's platform over the summer, promising expanded coverage with a broader group of contributors in the fall.

Importantly, the ATB's decision to uphold the assessment for purposes of the non-income measure of the corporate excise means that the "true debt" issue continues to be relevant for companies with cash management systems...

This afternoon, the Massachusetts Department of Revenue promulgated its Final Regulation 830 CMR 63.38.1: Apportionment of Income, to implement the market-based sourcing rules.

On July 1, 2004, the Internal Revenue Service issued Revenue Procedure 2004-39 setting forth procedures for determining whether a bond financed residential rental project is in compliance with the set-aside requirements contained in Section 142(d) of the Internal Revenue Code in the context of an acquisition/rehabilitation transaction or a new construction project.

Since the 2017 tax act enacted the new §163(j) limitation on interest deductions, multinationals have been asking whether the limitation applies to controlled foreign