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The IRS recently released final regulations (T.D. 9716) that clarify two issues under Section 162(m), which limits a public corporation's compensation deduction to $1 million per year for each covered employee.

The IRS reopened on Oct. 17 as Congress came to an agreement late Oct. 16 to fund the government and raise the debt ceiling.

In a private letter ruling (PLR 201341004), the IRS ruled that a valid spinoff had occurred notwithstanding that some of the distribution was related to hook stock in the parent.

The IRS ruled in a private letter ruling that a consent fee a debtor paid its creditors was a modification of the underlying debt.

Under Sections 871 and 881, interest must be paid on an obligation that is in registered form to qualify as portfolio interest.

There are many reasons that international tax changes are a poor fit to pay for highway funding and are unlikely be enacted outside of the context of broader business reform.

The IRS ruled that having more than one class of common stock with different fee structures did not cause preferential dividends by a REIT.

On Sept. 30, officials from Treasury and the IRS provided an update on a number of guidance projects relating to international tax.

The Obama administration recently submitted a budget proposal that asks for $1 trillion in new revenue and hundreds of tax changes.

Most of the tax provisions are designed to raise revenue, but the combined provisions raise less than $2 billion.

The idea of allowing companies a short-term opportunity to repatriate overseas earnings at a reduced rate has gained momentum as a possible revenue offset for highway spending.

House Speaker Paul Ryan, R-Wis., last week made a strong commitment to permanent tax reform, splitting sharply with key Republicans who would settle for a temporary bill in order to abandon revenue neutrality.

The Senate rejected a Democratic bill on June 6 that would have paid for a preservation of current federal student loan rates with three revenue-raising tax provisions.

Determining whether the SMLLC is a separate trade or business from the company is based on the taxpayer’s facts and circumstances.

Under Section 36B, the Affordable Care Act (ACA) created a new tax credit subsidy for certain taxpayers who obtain health insurance coverage under new state exchanges created by the law.

Self-directed IRAs, which allow the IRA owner to make direct investments in real estate or in non-publicly traded corporations, are increasingly popular.

A recent Tax Court case has created some uncertainty for cash-basis taxpayers regarding the treatment of material and supplies under the new final tangible property regulations.