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.

GLAM 2015-004 states that a general partner of a partnership, or a member-manager of an LLC, may sign a POA for purposes of the TEFRA examination or for other purposes of the partnership.

Proposed regulations released concurrently with the temporary regulations provide rules regarding the treatment as U.S. property of property held by a CFC in connection with certain transactions involving partnerships.

President Obama on Feb. 2 submitted a budget proposal for the government's 2016 fiscal year that includes a wide range of tax provisions designed to raise revenue...

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.

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%.

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).

Ultimately, the Tax Court rejected Marvel's arguments that the plain language of Section 108 proved that Congress intended that consolidated groups use a separate-entity approach.

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.

Treasury and the IRS recently issued final regulations (T.D. 9737) under Section 851(c), which relates to regulated investment company (RIC) controlled group rules.

Treasury has stated that a large impetus for the proposed changes was to address base erosion and profit shifting by multinational companies.

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.

The House Ways and Means Committee approved a bill last week that would repeal the medical device excise tax. That legislation will go to the House floor the week of June 15.

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.