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Searching Content indexed under Tax Authorities by David S. Miller ordered by Published Date Descending.
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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
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
3
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
4
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
5
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
6
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
7
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
8
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
9
New Tax Law (H.R. 1): Key Highlights Related To Interest Bearing Debt
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
United States
15 Jan 2018
10
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
11
Updates For Tax-Exempt Organizations From The Senate Bill
Early on December 2, 2017, the Senate passed the Tax Cuts and Jobs Act (the "Senate Bill").
United States
7 Dec 2017
12
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
13
The Tax Cuts And Jobs Act
Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the "Tax Cuts and Jobs Act".
United States
3 Nov 2017
14
Some Quick Thoughts On The "Big Six" Unified Framework
Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a "unified framework" for tax reform.
United States
3 Oct 2017
15
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
16
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
17
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
18
Final And Temporary Debt-Equity Regulations Issued By The IRS
The final and temporary regulations recharacterize certain debt instruments as equity for all federal income tax purposes.
United States
5 Nov 2016
19
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
20
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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