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Searching Content indexed under Tax Authorities by Richard M Corn ordered by Published Date Descending.
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1
Proposed Regulations On Built-In Gains And Losses Under Section 382(h)
On September 10, 2019, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury (the "Treasury")
United States
25 Sep 2019
2
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
3
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
4
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
5
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
6
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
7
House Of Representatives And Senate Conferees Reach Agreement On The Tax Cuts And Jobs Act (H.R. 1): Description Of The Conference Agreement And Differences From House And Senate Versions
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1), and released legislative text, an explanation...
United States
19 Dec 2017
8
House Of Representatives Passes The Tax Cuts And Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison Of The Bill Passed By The House And The Modified Senate Bill
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
United States
21 Nov 2017
9
IRS Issues Guidance On "North-South" Transactions
The Ruling, under the facts set forth under Situation 1, spells out the paradigmatic case of a "north-south" transaction.
United States
17 May 2017
10
Tax Court Rules That Extensions Of Variable Prepaid Forward Contracts Do Not Result In Taxable Exchanges
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical VPFC did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation...
United States
2 May 2017
11
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
12
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
13
Proposed Regulations Under Section 355 Clarify Device And Active Trade Or Business Requirements For Spin-Offs
If promulgated as proposed, the proposed regulations will affect distributing corporations and their shareholders and security holders in spin-offs, split-offs, and split-ups that occur on or after final regulations are published.
United States
29 Jul 2016
14
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
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