Searching Content indexed under Income Tax by Bernie Pistillo ordered by Published Date Descending.
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New Section 956 Regulations Expand Scope Of The New Participation Exemption But May Expose Borrowers To Increased Collateral Requirements
On October 31, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations that would limit the application of Section 956 of the Internal Revenue Code (the "Code")...
United States
14 Nov 2018
Trump Administration Officials And Congressional Leaders Release "Unified Framework" For Tax Reform
Similar to a one-page plan previously released by the Trump administration back in April, the Framework sets forth a sweeping set of potential tax reform objectives but is lacking in substantive detail.
United States
5 Oct 2017
Proposed IRS Debt-Equity Regulations: Aimed At Post-Inversion "Earnings Stripping," But May Also Impact Ordinary Related-Party Debt
On April 4th, the IRS issued proposed regulations under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax purposes.
United States
18 Apr 2016
Recently Proposed Treasury Regulations Regarding The Allocation Of Partnership Recourse And Nonrecourse Liabilities Contain Significant Changes For Many Routine Partnership Transactions
On January 29, 2014, the Internal Revenue Service and the Treasury Department issued proposed regulations modifying the rules under Section 752 regarding the allocation of recourse and nonrecourse partnership liabilities and clarifying some aspects of the disguised sale rules of Section 707.
United States
17 Feb 2014
A Year-End Rush for the Exit? Tax Uncertainty and Transactional Planning in Q3/Q4 2012
A combination of pending actual and potential tax increases effective in 2013 may have a significant impact on transactional planning in the third and fourth quarters of 2012.
United States
15 Aug 2012
2011 Report Of Foreign Bank And Financial Accounts ("FBAR") Due June 30
We wanted to remind our clients that Treasury Form TD F-90 22.1 "Report of Foreign Bank and Financial Accounts" (commonly known as the "FBAR") is due on June 30, 2012 with respect to the calendar year 2011.
United States
20 Jun 2012
Reasserting Its Role As Final Interpreter Of The Law, The Supreme Court Rejects IRS "Fighting Regulation" In United States v. Home Concrete & Supply, LLC, Et Al.
On April 25, 2012, the Supreme Court issued a 5-4 opinion, written by Justice Breyer, concluding that Treasury Regulation § 301.6501(e)-1(a)(iii) was invalid.
United States
8 May 2012
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