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  • Article

    Congress Works Through Budget Showdown Over Debt Ceiling, Government Funding And Tax Reform

    Congress appeared headed toward a government shutdown as the House voted on Sept. 29 to send a short-term government funding bill back to the Senate after attaching provisions to delay the implementation of health care reform for one year and repeal the medical device excise tax.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Conservation Deed Meets Substantiation Requirements For Charitable Deduction

    The Tax Court has concluded in "Averyt v. Commissioner" that the actual deed conveying a conservation easement to a charitable organization constituted a contemporaneous written acknowledgement.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Court Of Federal Claims Grants Corporation Refund For Disallowed Interest Deduction

    The Court of Federal Claims granted summary judgment in "Colorcon Inc. v. United States".
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Court Of Justice Of The European Union (CJEU) – Advocate General's Opinion

    The Advocate General has issued his opinion in the above case on 18 July 2013.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Democrats Propose Tax Increases To Replace Spending Sequestration

    President Obama and congressional Democrats are proposing to replace the impending spending "sequestration" with a variety of revenue-raising tax changes.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Democrats Propose Tightening Anti-Inversion Rules

    Sen. Carl Levin, D-Mich., and Rep. Sander M. Levin, D-Mich., Ways and Means ranking minority member, have introduced legislation to strengthen anti-inversion rules.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Final Regulations On Applying 2% Miscellaneous Itemized Deduction Floor To Estates And Trusts Issued

    The Treasury Department on May 8 issued final regulations on the application of the 2% miscellaneous itemized deduction floor to an estate or trust.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Gross Receipts From Sales Inappropriately Treated As Advertising Income

    In a recent IRS chief counsel advice memorandum (CCA 201626024) email, the IRS concluded that the taxpayer's gross receipts derived from the sale of its products were not domestic production...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Guidance Provides Safe Harbors For Recapitalizing Into Control To Effect A Section 355 Spinoff

    In a recent revenue procedure (Rev. Proc. 2016-40), the IRS provided two safe harbors for determining if a distributing corporation has control, within the meaning of Section 368(c), of a controlled...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    House And Senate Spar Over Tying Repatriation To Highway Spending

    Republican tax writers in the House and Senate deepened a divide last week over whether to use international tax reform and a tax on unrepatriated foreign earnings to help cover a highway funding shortfall.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    House Approves Permanent R&D Credit

    The administration threatened to veto the bill because of the estimated $182 billion cost, but indicated support for the underlying policy.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    House Republicans Seek To Impeach IRS Commissioner, Cut Agency Budget

    The House Judiciary Committee convened a hearing May 24 to examine House Republicans' misconduct charges against IRS Commissioner John Koskinen.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    International Tax Reform Heats Up

    Top congressional lawmakers have ramped up discussions over international tax reform as the outlook for business and comprehensive reform has dimmed.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Addresses Covered Transactions For Purposes Of Transaction Costs

    The IRS has issued a private letter ruling addressing whether an option to acquire a partnership interest should be taken into account for purposes of determining whether the buyer acquired the target partnership’s corporate subsidiaries in a "covered transaction."
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Announces Changes To The Employee Plans Determination Letter Program

    The IRS announced (Announcement 2015-19) important changes to the employee plans determination letter program for qualified retirement plans.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Approves Section 355 Spinoff Of A REIT Formed By A Partnership

    In private letter ruling 201436033, the IRS considered a transaction that involved the back-to-back distributions of a real estate investment trust.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Commissioner Warns Of Filing Season Delay

    IRS Commissioner John Koskinen warned that the IRS may have to delay the start of the 2015 filing season, as well as the processing of refunds.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Concludes Corporations Were Ignored For Asset Sale

    The IRS has concluded in field attorney advice that two corporations formed immediately prior to an asset sale were ignored for U.S. federal income tax purposes.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Concludes That Termination Fee Is Capital Loss Under Section 1234A

    The IRS concluded in field attorney advice (FAA 20163701F) that a fee related to the termination of a merger agreement resulted in a capital loss to a taxpayer under Section 1234A.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Determines Treatment Of Advance Payments Before And After Stock Acquisition

    The IRS determined what a taxpayer must do if it has deferred recognizing revenue into income under Rev. Proc. 2004-34 and its stock is subsequently acquired by an unrelated corporation...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP

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