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State Tax On Trust Income Based Solely On In-State Residence Of Beneficiaries Found Unconstitutional
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, "Kaestner").
United States
11 Jul 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
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
4
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
5
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
6
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
7
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
8
IRS Issues Taxpayer Advisory On Prepayment Of 2018 Property Taxes
The IRS announced yesterday, in IR 2017-210 (the "Advisory"), that state property taxes must be "assessed" in 2017 in order for such taxes to be prepaid in calendar year 2017 and therefore deductible in 2017.
United States
2 Jan 2018
9
Tax Planning is Crucial to Achieve Potential Spin-Off Benefits
Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions ...
United States
12 Oct 2017
10
BEPS: OECD Releases Multilateral Tax Treaty Convention
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting was released by the Organisation for Economic Co-operation and Development...
United States
9 Dec 2016
11
IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385
On October 13, 2016, the Treasury Department and the Internal Revenue Service (IRS) issued final and temporary regulations under section 385 of the Internal Revenue Code.
United States
27 Oct 2016
12
IRS Updates Ruling Policy On Corporate Business Purpose And Device Requirements Under Section 355
A brief background on private letter rulings and no-rule areas under Section 355 follows.
United States
31 Aug 2016
13
Proposed Regulations Under Section 355 Clarify Device And Active Trade Or Business Requirements For Tax-Free Spin-offs
First, the proposed regulations clarify the "device" test and its relationship to the "business purpose" requirement.
United States
29 Jul 2016
14
IRS Proposes Country-By-Country Reporting Regulations
On December 21st, 2015 the IRS proposed Country-by-Country reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations that may be shared with other taxing authorities under Information Exchange Agreements.
United States
8 Mar 2016
15
Proposed Treasury Regulations Aim To Curb Elective Treatment Of M&A Transaction Costs
Some taxpayers have taken the position that an acquiring corporation and a target corporation, when the target corporation is joining the acquiring corporation's consolidated corporate group, can choose between taking certain acquisition-related expenses into account in the target's pre-acquisition taxable year or the post-acquisition consolidated taxable year.
United States
1 Apr 2015
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