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  • 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 Activities It Won’t Accept For Section 199 Deduction

    The IRS Large Business and International (LB&I) Division has announced that it will not treat certain activities as manufacturing, producing, growing or extracting (MPGE)...
    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 Denies Bonus Depreciation For A Hotel Complex

    The IRS has released field attorney advice denying bonus depreciation to the owner and operator of a hotel complex because the taxpayer failed to demonstrate when costs were incurred for each property.
    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
  • Article

    IRS Discusses Section 199 Online Software Regulations And Application To Service Revenue

    The IRS addressed the appropriateness of applying the "self-comparable exception" and the "third party comparable exception" to determine if the gross receipts derived from the disposition of computer software qualified for purposes of Section 199.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Extends Transition Relief For WOTC

    The IRS has issued additional transition relief (Notice 2016-40) for employers who claim the work opportunity tax credit (WOTC) for employees hired between Jan. 1, 2015, and Aug. 31, 2016.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Finalizes Noncompensatory Partnership Option Regulations

    The IRS has finalized its 2003 proposed regulations on noncompensatory partnership options.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Finalizes Rules On Medical Device Excise Tax

    The IRS finalized its regulations on the medical device excise tax and released interim guidance that provides safe harbor rules for determining constructive sales price.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Further Postpones New Requirements For Estates To Report Asset Values

    Legislation enacted last July imposed new reporting requirements on estates filing estate tax returns after July 31, 2015.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Grants Extension For Electing Safe Harbor For Success-Based Transaction Fees

    The IRS has released a private letter ruling extending the time for a corporation to elect safe harbor treatment under Rev. Proc. 2011-29 for a success-based transaction fee.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Final Regulations On Allocation Of Mortgage Insurance Premiums

    The IRS has finalized regulations (T.D. 9588) that explain how to allocate prepaid qualified mortgage insurance (QMI) premiums.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP

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