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  • Article

    Proposed Treasury Regulations Relating To Foreign-Owned Domestic Disregarded Entities

    On May 10, 2016, the United States Treasury Department issued proposed regulations that would require information reporting by certain foreign-owned single member U.S. limited liability companies ("LLCs") and grantor trusts.
    United StatesTax
    Hughes Hubbard & Reed LLP
    Hughes Hubbard & Reed LLP
  • Article

    Prospects For U.S. Tax Reform Under President Trump

    The election of President Donald J. Trump, combined with Republican control of Congress, makes fundamental U.S. federal income tax reform more likely than at any time since the enactment of the Tax Reform Act of 1986.
    United StatesTax
    Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
  • Article

    PTEP: Recent Guidance On Inbound Transactions And Looking Ahead

    The article describes Notice 2024-16, which is welcome guidance for U.S. corporations considering an inbound liquidation or asset reorganization of a first-tier CFC.
    United StatesTax
    Steptoe LLP
    Steptoe LLP
  • Article

    Public Hearing On Proposed Regulations Set For December 4

    The Massachusetts Department of Revenue will hold its public hearing to discuss the proposed market-based sourcing regulation on December 4, 2014.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    Recent Developments In The State Taxation Of Pass-Through Entities

    In the complex and evolving world of state and local taxation, it is vitally important for the owners of pass-through entities to continually monitor changes in the law.
    United StatesTax
    Bradley Arant Boult Cummings LLP
    Bradley Arant Boult Cummings LLP
  • Article

    Relief From The BEIP Freeze?

    Unexpected relief may be coming for companies that are owed millions in unpaid incentive grants from New Jersey.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    Reminders For The 2018 Tax Filing (And Phishing) Season

    The Internal Revenue Service periodically reminds taxpayers and tax professionals to be careful in responding to fraudulent contacts using the IRS name or logo in telephone calls, unsolicited facsimiles ...
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Remote Workforce Doctrine And Policy: Short-Term And Long-Term Considerations

    Tim Noonan authored an article for the Columbia Law School Journal of Tax Law titled "Remote Workforce Doctrine and Policy: Short-Term and Long-Term Considerations."
    United StatesTax
    Hodgson Russ LLP
    Hodgson Russ LLP
  • Article

    Report From The Boston Bar Association Annual Tax Conference

    The Boston Bar Association held its annual tax conference this past Thursday, and as always the BBA pulled together a great lineup of practitioners, legislators, and Department of Revenue officials to discuss the latest in Massachusetts state tax.
    United StatesTax
    Reed Smith
    Reed Smith
  • Article

    Report On Temporary Regulations Addressing Notional Principal Contracts With Nonperiodic Payments

    The report comments on the temporary and proposed regulations published on May 8, 2015, relating to the treatment of nonperiodic payments made or received pursuant to notional principal contracts (NPCs).
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Residency vs. Domicile Checklist

    It is crucial to understand the difference between "domicile" and "residency." "Domicile" refers to a taxpayer's primary and permanent home, of which a tax payer can only have one...
    United StatesTax
    Donohue, O'Connell & Riley
    Donohue, O'Connell & Riley
  • Article

    Resolving Michigan Tax Disputes

    Governor Snyder signed a Public Act into law at the end of 2017 permitting a taxpayer and the Michigan Department of Treasury to engage in a settlement process during administrative appeals of Michigan sales tax ...
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Retailer Not Entitled To Bad Debt Sales Tax Credit

    The Supreme Judicial Court denied a retailer’s claim of a bad debt sales tax credit for sales made to customers that were eventually charged off as worthless debt.
    United StatesTax
    Pierce Atwood LLP
    Pierce Atwood LLP
  • Article

    "S Corporations: New Regulations, Back-To-Back Loans An Adjusted Basis Of S Corporation Debt," By Leigh Griffith, TAXES Magazine

    Article from Waller Law.
    United StatesTax
    Waller Lansden Dortch & Davis
    Waller Lansden Dortch & Davis
  • Article

    SB/SE Formally Establishes Fast Track Settlement Program

    The Appeals employee would assist in settling the matter between the IRS and the taxpayer.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Secretary Yellen Says Consensus Is Near On International Corporate Tax Agreement

    In remarks following the G20 Finance Ministers and Central Bank Governors meetings, Secretary of the Treasury Janet L. Yellen stated that 132 countries are coming to a consensus around a global corporate minimum tax rate of at least 15 percent.
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    Section 1202 – Qualified Small Business Stock

    The tax code includes a number of provisions that benefit small businesses and small business owners. One of these provisions is contained in Section 1202 which provides for an exclusion of up to 100%
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Section 965 Proposed Regulations Issued

    On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act.
    United StatesTax
    Butler Snow LLP
    Butler Snow LLP
  • Article

    Self-Compliance Check For 403(b) Plans

    The IRS in 2011 sent a Section 403(b) compliance check questionnaire to a national sample of more than 300.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Senate Amendment Proposes Changes to "Carried Interest" Legislation

    Following its Memorial Day recess, the U.S. Senate has taken up consideration of H.R. 4213, the bill containing the proposed changes to the taxation of carried interest as a revenue offset, passed by the House of Representatives on May 28.
    United StatesTax
    Goodwin Procter LLP
    Goodwin Procter LLP
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