Tax News
Bringing you the latest tax and accounting updates
A Primer On Education Tax Credits
When preparing for college, students and parents can easily list the costs like tuition, fees, supplies and room and board. But do you spend enough time considering the tax benefits associated with a college education? Lucky for you there are a number of education tax...
IRS – Tax Tips
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Proposed Partnership Audit Regulations Reissued in Substantially Identical Form
by Annie Kim, Arnold P. May and Jo Habenicht on June 14, 2017 at 2:34 pm
On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit regime. The centralized partnership audit regime was enacted in November 2015 by Section 1101 of the Bipartisan Budget Act of 2015, P.L. 114-74, and...… Continue Reading […]
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IRS Updates FATCA FAQs, Addresses January Temporary Regulations
by Martine Seiden Agatston, Martin T. Hamilton and Amanda H. Nussbaum on April 25, 2017 at 9:49 pm
On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online.[1] These additional FAQs clarify recent temporary regulations (the “Temporary Regulations”) requiring that a beneficial owner withholding certificate contain a foreign taxpayer identification number (“TIN”) and,...… Continue Reading […]
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Final and Temporary Debt-Equity Regulations Issued by the IRS
by David S. Miller and Janicelynn Asamoto Park on November 2, 2016 at 3:46 pm
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain debt instruments as equity for all federal income tax purposes. The final and temporary regulations narrow considerably the scope of the proposed regulations...… Continue Reading […]
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IRS Updates Ruling Policy on Corporate Business Purpose and Device Requirements under Section 355
by Martin T. Hamilton, Amanda H. Nussbaum, Stuart Rosow and Stephen Severo on August 29, 2016 at 8:26 pm
The U.S. Internal Revenue Service (“IRS”) released Revenue Procedure 2016-45 (the “Revenue Procedure”) on August 26, 2016, permitting taxpayers once again to seek private letter rulings on issues of “corporate business purpose” and “device” under Section 355 of the U.S. Internal Revenue Code of 1986, as amended (dealing with tax-free spin-offs and related transactions). The corporate...… Continue Reading […]
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IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return
by Joshua Miller and Gabriella Ahdoot on August 9, 2016 at 5:00 pm
The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted stock granted in connection with the performance of services generally becomes taxable as ordinary income compensation when it is no...… Continue Reading […]