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The IRS has appealed its loss on in the Tax Court in Medtronic, Inc. v. Commissioner to the Eighth Circuit Court of Appeals.

Recently proposed regulations issued by the IRS under Section 752 provide technical rules concerning related parties and areas of overlapping economic risk of loss.

The IRS and the Tax Court have each recently addressed whether stock cannot be considered preferred stock because it participates in corporate growth to a significant extent.

Under the proposed regulations, taxpayers are given the option to use either the simplified production method (as exists in the current regulations) or a modified simplified production method.

The next-day rule, however, is an exception to the end-of-day rule under the current regulations.

The IRS concluded that the partners are subject to self-employment tax on their distributive shares of management company income.

Last week, the Supreme Court of Canada released its decision in Grant Thornton LLP v. New Brunswick. The judgment provides important guidance on interpreting and applying the basic two-year limitation period contained...

Employers who run retirement plans should periodically do system-wide due diligence to make corrections. Errors happen, from simple clerical mistakes to systematic failures in the record-keeping system.

The Affordable Care Act requires applicable large employers to offer minimum essential coverage to their full-time employees.

The emergence of cloud solutions has generated considerable excitement due to the potential they have to transform the way companies operate.

California Governor Jerry Brown is proposing significant changes in his revised budget proposal for the 2013-2014 fiscal year to the California Enterprise Zone Program.

The court agreed, holding that the refund claim wasn’t timely and granted the government’s motion to dismiss.

The U.S. Court of Federal Claims has ruled in Sutardja v. United States that stock options granted to an employee were deferred compensation subject to Section 409A, pending a ruling on the fair market value of the underlying stock on the grant date.

Please join us for our webcast Cross-border mergers & acquisitions update for a discussion on recent guidance issued by the IRS and Treasury Department in the cross-border mergers and acquisitions (M&A) area.Joe Calianno, Grant Thornton’s International Technical Tax practice leader, will be joined by Brenda Zent, international tax specialist in the U.S. Department of the Treasury’s Office of International Tax Counsel, as presenters for this event.

The IRS ruled on May 24, 2012 (PLR 201234006), that an excess servicing spread acquired by a real estate investment trust (REIT) as defined in Section 856 was an interest in mortgages on real property and that the related interest income will qualify for purposes of determining whether the REIT satisfied the gross income tests of sections 856(c)(2) and 856(c)(3).

Stock options’ last hurrah? Well, maybe. Human resources leaders and CFOs need to know that executives who possess, as a group, $22.5 billion of vested, unexercised, in-the-money stock options,1 could exercise those stock options as we approach year-end.

The IRS provided rules on Sept. 18 for allocating pretax and after-tax amounts among disbursements made to multiple destinations from a qualified retirement plan.