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  • Article

    Proposed Code Sec. 367 Regulations Attempt To Tax Foreign Goodwill And Going Concern Value

    The transfer of foreign goodwill and going concern value by a domestic corporation to a foreign subsidiary for use in a trade or business outside the United States has never been subject to taxation under Code Sec. 367.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Proposed Regulations Provide Guidance On Minimum Value Of Employer-Sponsored Coverage

    An employer-sponsored health plan provides minimum value if the plan's share of total allowed costs of benefits provided to an employee is at least 60%.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
Article

Regulations Provide Guidance For New Program For Professional Employer Organizations

The IRS has issued temporary (TD 9768) and proposed (REG-127561-15) regulations implementing a new voluntary certification program for professional employer organizations (PEOs).
United StatesTax
Grant Thornton LLP
Grant Thornton LLP
  • Article

    Relevant Again: Saving Loans For REMICs

    Under the REMIC rules, a mortgage loan ceases to be a good REMIC asset if the borrower replaces the real property collateral with government securities (known as defeasance) less than two years...
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    Reminder Of Filing Deadline Changes

    The IRS has reminded employers of filing deadline changes related to Form W-2, Wage and Tax Statement, made by the Protecting Americans from Tax Hikes Act of 2015 (PATH Act).
    United StatesTax
    Brown Smith Wallace
    Brown Smith Wallace
  • Article

    Renewal Of Tax-Free Transfers To Charity By IRAs

    For this limited time, an IRA owner, who is 70½ or older, can directly transfer, tax-free, up to $100,000 to an eligible charity.
    United StatesTax
    Nutter McClennen & Fish LLP
    Nutter McClennen & Fish LLP
  • Article

    Revised Common Level Ratio For Philadelphia May Result In Tax Refund

    Every year, the Commonwealth of Pennsylvania State Tax Equalization Board ("STEB") establishes a common level ratio ("CLR") of assessed value to market value of real estate for each of Pennsylvania’s 67 counties for the prior calendar year, which are to be issued by the July 1 effective date.
    United StatesTax
    Duane Morris LLP
    Duane Morris LLP
  • Article

    Ryan LoRusso Featured In Forbes' Article "Why Billionaire Mark Cuban Just Wired $280 Million To The IRS"

    On the heels of billionaire Mark Cuban's recent comments regarding his multimillion-dollar tax bill, Withers Private Client and Tax partner, Ryan LoRusso spoke to Forbes...
    United StatesTax
    Withers LLP
    Withers LLP
  • Article

    SALT Top Stories Of 2016

    The year 2016 may best be remembered as a time when many fundamental issues were set up for dynamic resolution in the coming year.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Senate Budget Committee's $1.5 Trillion Tax Cut Could Be Critical For Tax Reform

    Top Senate Budget Committee members announced an agreement last week to write a budget that accommodates large tax cuts.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Senate Budget Committee Calls For More IRS Criminal Referrals To The DOJ

    According to Law360, the Senate Budget Committee recently held a hearing regarding offshore tax evasion where senators made clear that, in their view, the IRS is not making enough criminal referrals to the Department of Justice.
    United StatesTax
    Katten
    Katten
  • Article

    Senate Confirms New IRS Commissioner

    The US Senate has confirmed Daniel Werfel as the next commissioner of the Internal Revenue Service (IRS). The Senate voted 54-42, achieving bipartisan support for the nominee.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Senate Democrats Push For Revenue Neutral Tax Reform Outside Reconciliation

    Senate Democrats released a public letter last week offering to work with Republicans on tax reform as long as the bill is revenue neutral and does not use the reconciliation process or provide a tax cut...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Shipping Fees Soon Not Taxable In Missouri?

    A 2015 Missouri Supreme Court decision raised taxes on Missouri businesses that charge or pay for shipping fees.
    United StatesTax
    Brown Smith Wallace
    Brown Smith Wallace
  • Article

    Sideman Tax Alert: IRS Plans Major Increase In Audit Rates

    On May 2, 2024, the IRS released an update on its Strategic Operating Plan which includes among its main objectives...
    United StatesTax
    Sideman & Bancroft
    Sideman & Bancroft
  • Article

    Sixth Circuit Denies Rehearing Of "Quality Stores" Decision On Severance Pay FICA Taxes

    The Sixth Circuit Court of Appeals has denied an IRS request for a rehearing of the "United States v. Quality Stores, Inc." decision.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Special Tax Edition

    The Indian Tribal Governments practice published its latest edition of the Tribal Business Journal recently, dedicating the edition to federal tax issues.
    United StatesTax
    Drinker Biddle & Reath LLP
    Drinker Biddle & Reath LLP
  • Article

    State + Local Tax Insights: Summer Issue 2018

    Statutes mean what they say. As the late Justice Scalia once quipped, the proper role of the courts "is to apply the text, not to improve upon it.
    United StatesTax
    Morrison Foerster
    Morrison Foerster
  • Article

    Success-Based Fees: Elect The Safe Harbor Or Document Thoroughly

    When taxpayers pay fees contingent on the successful closing of certain "covered transactions," including, for example, taxable acquisitions of assets that constitute a trade or business, ...
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Succession Planning for Entrepreneurs…Why 2013 May Be Too Late

    Entrepreneurs consistently face the difficulty of passing the family business to younger generations. Among the many challenges to successful transitions is the cost of estate, gift and generation-skipping taxes (GST) payable on transfers to family members.
    United StatesTax
    WTAS
    WTAS
  • Showing 901–920 of 9341 results

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