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  • Article

    IRS Announces Procedures For Post-Appeals Mediation

    The IRS on Dec. 12 issued http://www.irs.gov/pub/irs-drop/rp-14-63.pdf Rev. Proc. 2014-63, which consolidates prior guidance related to the types of cases that may be mediated in appeals.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Changes Filing Address For Form 3115 Automatic Change Requests

    Effective immediately, the IRS has changed the address for filing the duplicate copy of a completed Form 3115, "Application for Change in Accounting Method," for an automatic method change request.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Clarifies And Updates Guidelines On FICA Withholding On Tips

    The IRS has clarified and updated guidelines (Rev. Rul. 2012-18) first presented in 1995 (Rev. Rul. 95-7) concerning FICA taxes imposed on tips and the notice and demand rules under Section 3121(q).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Extends Deadline For Biodiesel Mixture And Alternative Fuel Credit Payments

    The IRS has published transition relief that extends taxpayers' ability to claim payments for the biodiesel mixture credit and the alternative fuel credit on Form 8849 until July 1, 2013.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Highlights ACE Adjustment In Conclusion On Built-In Loss Under Section 382

    The IRS has concluded in a heavily redacted legal memorandum that a taxpayer improperly determined that a subsidiary was a net unrealized built-in gain company at the time of acquisition.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Final Regulations Regarding Partial Pension Annuities

    The IRS issued final regulations (T.D. 9783) that provide guidance relating to the minimum present value requirements that apply to certain defined benefit pension plans.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues New, Revised Procedures For Filing Accounting Method Changes

    The IRS recently released two Revenue Procedures that provide a comprehensive update to the procedures for filing both automatic and non-automatic accounting method changes.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Proposed Regulations On Device And Active Trade Or Business Requirements Under Section 355

    The IRS issued proposed regulations (REG-134016-15) that provide guidance under Treas. Reg. Secs. 1.355-2 and -9 to address concerns regarding the spinoff of too many nonbusiness assets relative to...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Proposed Regulations Regarding Tax Attributes In Asset Reorganizations

    The IRS issued proposed regulations that would modify the definition of "acquiring corporation" for purposes of determining the location of earnings and profits.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Proposes Regulations On ACA Reporting Requirements

    The IRS proposed regulations ( REG-103058-16) relating to information reporting of minimum essential coverage under Section 6055...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Provides Final And Temporary Regulations On Controlled Group Allocation Of R&D Credit

    The IRS has provided final and temporary regulations (T.D. 9717) on the allocation of the research and development (R&D) tax credit to members of a controlled group.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Reiterates Who May Sign Partnership Return

    Section 6063 states that a partnership return must be signed by any one of the partners and that a partner’s signature is prima facie evidence that the partner is authorized to sign the return on behalf of the partnership.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Rules That A Pharmaceutical Company Is A Qualified Trade Or Business For Purposes Of Section 1202

    The IRS ruled that a corporation that provides products and services to the pharmaceutical industry was engaged in a qualified trade or business for purposes of Section 1202.
    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 Supplements Prior Spinoff Ruling Following Taxpayer Delay

    In a private letter ruling (PLR 201505013), the IRS supplemented its previous ruling in PLR 201437013 and addressed issues related to a delay in the expected consummation of a spinoff.
    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

    IRS User Fees Likely To Increase

    The IRS expects to revise a number of existing user fees and to implement new user fees for some additional services in the "near future," the agency said.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    North Carolina Enacts Budget Legislation Reducing Income Tax Rates, Providing Sales Tax Exemptions

    During June 2017, the North Carolina legislature passed legislation that included various income tax and sales tax provisions as part of the state budget. Gov. Roy Cooper vetoed the state's budget bill...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Senate Vote Shows Support For Repeal Of Medical Device Tax, But Legislation Not Likely

    The Senate recently voted 79–20 in a show of support for repealing the medical device excise tax, but legislation to actually repeal the tax still does not appear likely in the near term.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Sponsors Of Individually Designed Government Plans May Elect To Delay Their Determination Letter Application By Two Years

    The IRS gave sponsors of individually designed government plans (Rev. Proc. 2012-50) the option to use either Cycle C or Cycle E as their second remedial amendment cycle for filing a determination letter application.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP

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