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Searching Content by Amanda Nussbaum ordered by Published Date Descending.
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1
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
2
Section 1446(f) Proposed Regulations: Key Guidance On Partnership Interest Transfers By Non-U.S. Persons
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
United States
6 Jun 2019
3
Players, Staff And Draft Picks May Be Traded Tax-Free Under New Safe Harbor
On April 11, 2019, the Internal Revenue Service (the "IRS") issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts
United States
14 May 2019
4
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
5
Parsonage Exclusion Found By Seventh Circuit To Be Constitutional
On March 15, 2019, the U.S. Court of Appeals for the Seventh Circuit held in Gaylor v. Mnuchin that the tax exemption for "ministers of the gospel" (defined below) under Section 107(2)
United States
17 Apr 2019
6
Five Excise Tax Tips For Tax-Exempt Employers
As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect many tax-exempt employers.
United States
21 Mar 2019
7
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
8
Proposed Rental Business Safe Harbor Under Section 199A
On January 18, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury issued final regulations on the "pass through" deduction under section 199A[1] of the Internal Revenue Code (the "Code").
United States
13 Feb 2019
9
Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
United States
30 Jan 2019
10
IRS Releases Interim Guidance On New Excise Tax On Executive Compensation Paid By Tax-Exempt Organizations
On December 31, 2018, the Department of the Treasury ("Treasury") and the Internal Revenue Service (the "IRS") released Notice 2019-09 (the "Notice"),
United States
18 Jan 2019
11
The Proposed BEAT Regulations
On December 13, 2018, the Internal Revenue Service and the Department of the Treasury released proposed regulations with respect to the "base erosion and anti-abuse tax" under section 59A of the Internal Revenue Code.
United States
7 Jan 2019
12
Tax Reform: UBTI Guidance On Qualified Transportation Fringe Benefits
From Proskauer's Not For Profit / Exempt Organization Blog, a discussion of recent IRS guidance and New York State legislative relief on Internal Revenue Code 512(a)(7)
United States
28 Dec 2018
13
Inclusion Of Qualified Transportation Fringe Benefits In UBTI: Guidance, Relief, And Rumors Of Possible Repeal
December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the "Code"), which requires tax-exempt employers ...
United States
28 Dec 2018
14
FATCA: Significant Relief In New Proposed Regulations
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
United States
21 Dec 2018
15
Summary Of The Opportunity Zone Program
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program.
United States
14 Nov 2018
16
Proskauer's 23rd Annual Trick Or Treat Seminar
Amanda Nussbaum welcomed everyone and briefly discussed the five major trends impacting tax-exempt organizations today, including the general impact of the Tax Cuts and Jobs Act (the "Act")...
United States
13 Nov 2018
17
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
18
Tax-Exempts May Limit Fund Investments Pursuant To New IRS Guidance On UBTI
On August 21, 2018, the Internal Revenue Service ("IRS") released Notice 2018-67 (the "Notice"), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6)
United States
5 Sep 2018
19
Treasury And IRS Issue Proposed "Pass-Through Deduction" Regulations
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction"
United States
31 Aug 2018
20
Impact of Recent Tax Legislation On M&A Transactions
This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the "Tax Act") that may affect M&A Transactions.
United States
12 Feb 2018
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