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  • Article

    Target Company Does Not Join Consolidated Group Until Stock Released From Escrow, IRS Memo Concludes

    The IRS concluded that a target corporation did not join the purchasing corporation’s consolidated group until the target’s stock was released from escrow.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Tax Writers Done Teeing Up Tax Reform But Set No Timetable For Legislation

    Congressional tax writers are nearing the end of a two-year process of setting the stage for tax reform through hearings and discussion drafts, but have yet to announce any plan to actually begin marking up a bill.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Treasury Issues Proposed Regulations On Expatriate Health Plans

    Recently released proposed regulations provide rules for expatriate health plans, expatriate health plan issuers and qualified expatriates under the Expatriate Health Coverage Clarification Act of 2014.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Treasury Proposes Revising FBAR Rules For Certain Financial Professionals

    If finalized, the proposed regulations ( RIN 1506-AB26) would amend the FBAR regulations by eliminating the current signature authority filing requirement exemptions and adding a simplified and expanded exemption.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Ways And Means Votes To Overhaul Charitable Organization Rules

    Many of the bills are direct responses to the IRS's heavily criticized handling of investigations into the tax-exempt status of many organizations in 2012 and 2013.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Will Not Impose The Simplified Production Method On Restaurants

    In an IRS chief counsel advice memorandum released Sept. 26 http://www.irs.gov/pub/irs-wd/201439001.pdf (CCA 201439001), the IRS concluded that it generally would not support imposing the simplified production method on restaurants if the taxpayers are willing to develop and implement a reasonable facts-and-circumstances method instead.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    When The Clock Starts Ticking: Supreme Court Of Canada Speeds Up The Clock For Discoverability Of Claims

    Statutes of limitations in Canadian provinces generally bar plaintiffs from bringing claims against a defendant within a specified period of time from the date on which the plaintiff knew or reasonably ought to have known they had a claim against a defendant...
    CanadaLitigation, Mediation & Arbitration
    Fasken
    Fasken
  • Article

    IRS Updates Letter Ruling Procedures, Modifies User Fees

    The IRS recently issued its annual revenue procedure updating the procedures for requesting private letter rulings (PLRs) and extensions of time for missed elections from the IRS Office of Chief Counsel.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Year-End Tax Guides 2016 From The Washington National Tax Office

    Tax planning means planning ahead. With that in mind, Grant Thornton LLP has put together three year-end tax guides designed to address the complex tax issues you're worrying about in 2016.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Senate Tax Writers Make Business And International Tax Reform Recommendations

    The Senate Finance Committee released five reports from its tax reform working groups this week that offer recommendations for international and business tax reform.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Rules That Interest In Money Market Fund Is Cash Item For REIT Asset Test

    The IRS has ruled (Rev. Rul. 2012-17) that an investment by a real estate investment trust (REIT) in a money market fund is an investment in "cash or cash items" for purposes of the REIT asset test.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Updates No-Rule List, Procedures For Obtaining Letter Rulings

    The IRS on Jan. 4 released its annual procedures for obtaining private letter rulings and determination letters, as well as its list of types of issues for which the Office of Chief Counsel would not give a ruling.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    EU Council Reaches Agreement Expanding Hybrid Mismatch Rules

    On Feb. 21, 2017, the Council of the European Union (EU Council) reached agreement on the terms of a draft that expanded Anti-Tax Avoidance Directive (ATAD 2).
    European UnionTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    New Developments Summary - Accounting For Financial Instruments

    The guidance in ASU 2016-01 is effective for "public business entities," as defined, for fiscal years beginning after December 15, 2017, including interim periods within those fiscal years.
    United StatesAccounting and Audit
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    On The Horizon - May 7, 2013

    The Board has issued a proposal to indefinitely defer the effective date for disclosing unobservable inputs in Level 3 fair value measurements of investments held by a nonpublic employee benefit plan in its private company plan sponsor.
    United StatesAccounting and Audit
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Guidance On Use Of Electronic Media For Employer-Provided Qualified Transportation Benefits

    In a revenue ruling issued Nov. 21 the IRS provided guidance on employers’ use of smartcards, debit and credit cards, and other electronic media to provide qualified transportation benefits to employees.
    United StatesEmployment and HR
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Brady Lowers Expectations For Tax Reform After Winning Ways And Means Gavel

    Brady's first order of business will be to help negotiate an agreement with the Senate over the 50-plus extender tax provisions that expired at the end of 2014.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Case Alert: Court Of Appeal - Judgment - HMRC v Pendragon Plc

    The Court of Appeal has issued its judgment in the case of Pendragon Plc, restoring the First-Tier Tribunal's decision.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Congress Aims To Address Expired Provisions And International Reform After Recess

    Congress is set to return from the August recess on Sept. 8 to a full agenda that includes big tax priorities such as extending expired tax provisions and attempting international tax reform.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Congress Passes Budget Slashing IRS Funding As Debt Ceiling Approaches

    President Obama signed into law an omnibus appropriations bill on Jan. 17 that leaves the IRS with $11.3 billion in funding for fiscal year 2014.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP

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