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The IRS finalized regulations under Treas. Reg. Sec. 1.304-4 containing certain anti-abuse provisions for Section 304 related to party stock sales.

On October 14, 2008, the Internal Revenue Service (“IRS”) issued Notice 2008-100 to provide tax relief for financial institutions that sell stock to the Department of the Treasury (“Treasury”) under the Capital Purchase Program (“CPP”).

The IRS has issued temporary regulations (T.D. 9598) under Section 988 related to integrated transactions that involve foreign currency denominated debt under Treas. Reg. Sec 1.988-5.

With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules.

In fall 2013 the IRS issued Notice 2013-54 to provide guidance on how the market reforms of the Affordable Care Act (ACA) apply to health reimbursement arrangements (HRAs).

In a private letter ruling http://www.irs.gov/pub/irs-wd/201450011.pdf (PLR 201450011), released on Dec. 12, the IRS said that a corporation could take a bad debt deduction under Section 166 related to payments made to a disputed ownership fund under Treas. Reg. Sec. 1.468B-9.

In Private Letter Ruling (PLR) 201214020, the IRS ruled that under Section 1504(a)(3), a spun-off corporation (Controlled) was not a "successor" to a distributing corporation (Distributing).

The IRS has released new guidance (Rev. Proc. 2012-39) modifying and clarifying the procedures for accounting method changes involving Section 381(a) transactions.

Freedom from some state and local communications excise taxation soon may no longer be one of the advantages of Voice-Over-Internet-Protocol (VOIP) services. The New York State Public Service Commission (NY-PSC) has just issued a decision classifying Vonage Holdings Corporation, a provider of VOIP services that utilize the public Internet, as a "telephone corporation." While not a tax decision per se, this decision has tax implications for both service providers and end-users.

New York taxpayers generally do not greet new taxes with enthusiasm, but New York's new pass-through entity tax ("PET") is poised to provide some relief to rising personal tax rates—and an exception to this rule.

Congressional tax writers spent much of last week debating anti-inversion tax proposals.

Many banks these days are investing in affordable housing projects to fulfill their CRA obligations, as well as to gain tax advantages from these "low income housing credit (LIHC)" investments.

The Massachusetts Department of Revenue has indicated it is looking to expand taxpayer eligibility for its early mediation program for expedited settlement of tax disputes by including taxpayers with smaller proposed tax assessments.

ABA Business Section Newsletter for Nonprofit Organizations

On September 23, 2014, the District of Columbia Council enacted market-based sourcing provisions for sales of intangibles and services as part of the 2015 Budget Support Act (BSA).

The Alabama Department of Commerce has adopted rules regarding the Alabama New Markets Development Act, which implemented Alabama’s New Markets Tax Credit.

The Bipartisan Budget Act of 2015 (the "BBA"), signed into law on November 2, 2015, substantially changes partnership audit rules.