The IRS Office of Chief Counsel issued a chief counsel advice (CCA) memorandum (CCA 201619008) to the Large Business and International Division regarding the deductibility of certain disgorgement payments.

The IRS recently issued proposed regulations under Section 409A that apply to nonqualified deferred compensation.

The IRS Large Business and International (LB&I) Division set a May 1 effective date for certain changes in the examination process for large taxpayers.

The IRS has offered a package of administrative relief for taxpayers affected by Hurricanes Harvey and Irma.

In Situation 1 of the Rev. Rul., Parent owns all the stock of Distributing, which owns all the stock of Controlled. On Date 1, Parent purports to contribute $25x of property of Controlled in...

The IRS has issued Rev. Proc. 2016-33 to provide additional details on how a business entity can become certified under the IRS's new certified professional employer organization (CPEO) program.

The IRS recently released a new version of the Form 3115, "Application for Change in Accounting Method," along with 23 pages of instructions.

In Notice 2017-09, the IRS provided guidance on the safe harbor for de minimis and inadvertent errors in amounts reported on information returns.

Section 61 generally states that gross income includes all income from all sources, but Section 118(a) provides an exception for contributions to the capital of a corporation.

Senate Republicans have been involved in the high-level discussions, but have been less aggressive in formulating their own proposals.

Oklahoma's legislative session adjourned on May 26, with Gov. Mary Fallin signing a series of measures as a means to temporarily resolve the state's significant budget issues.

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

The year 2016 may best be remembered as a time when many fundamental issues were set up for dynamic resolution in the coming year.

Top Senate Budget Committee members announced an agreement last week to write a budget that accommodates large tax cuts.

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...

In Petersen v. Commissioner, 148 T.C. No. 22 (June 13, 2017), the Tax Court addressed the application of Section 267(a)(2) to an S corporation that maintains an employee stock ownership plan (ESOP).

New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.

Trump has embraced the concept of a ‘border adjusted' tax, though he stopped short of specifically endorsing the border adjustability provision at the heart of the House Republican tax plan.

On the individual side, Trump proposed a full deduction of the "average cost of child care spending" and a repeal of the estate tax.

Senate Finance Committee ranking minority member Ron Wyden, D-Ore., has released a discussion draft of legislation that would overhaul the tax rules on retirement accounts.