Searching Content indexed under Tax Authorities by Arnold & Porter ordered by Published Date Descending.
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IRS Issues Proposed Regulations Clarifying FIRPTA Exemption For Qualified Foreign Pension Funds
On June 6, 2019 the US Internal Revenue Service and US Department of the Treasury issued proposed regulations that provide guidance with respect to (1) the scope of the exception for a "qualified foreign pension fund" ...
United States
20 Jun 2019
2020 Presidential Election Watch: Democratic Candidates Call For Higher Estate Tax And Lower Exemption
The Tax Cuts and Jobs Act (TCJA), signed into law on December 22, 2017, was the most significant change in the federal tax law since 1986. Although the TCJA ...
United States
4 Apr 2019
IRS Announces Much-Anticipated Updated Voluntary Disclosure Procedure
When the United States Internal Revenue Service announced in March 2018 that it would be terminating the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018,
United States
28 Dec 2018
How To Review The Form 990: What's Important To Funders, Watchdogs And The Public?
The IRS Form 990 is more than a tax return, it's a public statement about your nonprofit's financial, programmatic and governance activity for the year.
United States
3 Dec 2018
Konzernklausel des § 6a GrEStG nach Generalanwalt beim EuGH keine verbotene Beihilfe
Mithilfe der Vorschrift des § 6a GrEStG können grundstückbesitzende Unternehmen und Konzerne Umstrukturierungen durchführen ...
28 Sep 2018
The Tax Cuts And Jobs Act: Providing For Tax Savings While Investing In "Opportunity Zones"
The Tax Cuts and Jobs Act, passed in December 2017, offers new tax incentives for taxpayers investing through special vehicles known as "qualified opportunity funds" in certain economically distressed areas ...
United States
27 Sep 2018
IRS Announces Last Chance For Taxpayers With Undisclosed Foreign Assets To Enter The Offshore Voluntary Disclosure Program
On March 13, 2018, the United States Internal Revenue Service issued News Release 2018-52 announcing that it will begin to ramp down the Offshore Voluntary Disclosure Program ...
United States
20 Mar 2018
New Law On The Tax-Deductibility Of False Claims Act And Other Government Settlements
Regardless, anyone who negotiates a settlement with the government should understand the new law well ahead of any resolution.
United States
26 Jan 2018
Overview Of The Tax Cuts And Jobs Act
On December 22, 2017, President Trump signed a new tax bill into law, informally referred to as the Tax Cuts and Jobs Act (Tax Act).
United States
16 Jan 2018
Grecian Magnesite Decision Could Have Significant Tax Implications For Non-Us Investors In A US Fund
In a recent case, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the Tax Court declined to follow the longstanding position of the IRS in Revenue Ruling 91-32 that a non-US partner...
United States
28 Sep 2017
The IRS Re-Publishes Proposed Regulations On The New Partnership Audit Regime
The Department of the Treasury and the IRS have published proposed regulations under the centralized partnership audit regime that was enacted into law under the Bipartisan Budget Act of 2015.
United States
12 Jul 2017
Preparing Your Estate Plan For Tax Reform
On April 25, 2017, the White House announced its plan for tax reform, in an outline called "2017 Tax Reform for Economic Growth and American Jobs" (the White House Plan).
United States
14 Jun 2017
Avoiding Falling Foul Of The Criminal Finances Act
New legislation could leave engineering firms vulnerable to fines if their subcontractors are involved in tax evasion.
1 Jun 2017
Latin American And Caribbean Financial Institutions: Potential Impact Of The US Elections
Financial institutions in Latin America and the Caribbean should consider the potential opportunities that have arisen as a result of the recent US elections.
United States
27 Feb 2017
A Charitable Gift Receipt Is Worth A Lot More Than The Paper It Is Written On—Tax Court Denies $64 Million Deduction Due To Defective Donation Acknowledgment
In 15 West 17th Street LLC v. Commissioner, the US Tax Court denied a $64.5 million deduction claimed by the taxpayer for a charitable contribution to a historic preservation organization in 2007.
United States
8 Feb 2017
Get A Hold Of Your QSBS Holding Period
As originally enacted in 1993, Section 1202 of the Internal Revenue Code introduced a 50 percent exclusion from taxable gain on the sale of so-called QSBS held by an individual for more than five years.
United States
3 Feb 2017
Tax Alert: G20 Leaders Approve OECD Proposals For Comprehensive Global Reform Of The International Tax System, Including Redefinition Of "Permanent Establishment"
G20 finance ministers last week finally approved the wide-ranging "BEPS" reforms to the international tax system.
United States
19 Nov 2015
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