Legal Articles: Caplin & Drysdale, Chartered

 







Document(s) published by this organization: 25


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HTMLSyndicated Conservation Easement Transactions Indentified as New "Listed Transactions"
Arianna Caldwell, Christopher S. Rizek, Charles M. Ruchelman; Caplin & Drysdale, Chartered;
Legal Alert/Article
January 11, 2017, previously published on January 3, 2017
On December 23, 2016, the Internal Revenue Service (“IRS”) issued Notice 2017-10 identifying certain transactions involving conservation easements as “listed transactions.” For several years the IRS has been actively examining conservation easements and litigating such cases...

 

HTMLCongress Looks to Fix New Partnership Audit Rules
Jonathan S. Brenner, Rachel Leigh Partain, Charles M. Ruchelman, Elizabeth J. Stevens; Caplin & Drysdale, Chartered;
Legal Alert/Article
January 6, 2017, previously published on December 14, 2016
The Bipartisan Budget Act of 2015 (“BBA”) fundamentally changed the rules by which partnerships, and entities taxed as partnerships, interact with the Internal Revenue Service (“IRS”) in an audit or litigation. We outlined these significant changes to the partnership audit...

 

HTMLQualified Retirement Plans in 2017 and Beyond: Resources & Considerations for Employers
Ronald G. Cluett, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 30, 2016, previously published on December 29, 2016
In Revenue Procedure 2016-37, the IRS formally announced the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed, qualified retirement plans.1 The IRS further announced that it would publish each year a Required Amendments List...

 

HTMLTax Plans Compared (December 2016) Corporate Tax
Mark D. Allison, Peter A. Barnes, Jonathan S. Brenner, Kirsten Burmester, Richard W. Skillman; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 20, 2016, previously published on December 16, 2016
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump’s proposal and Speaker of the House Paul Ryan’s proposal on key corporate tax provisions applicable to U.S. domestic and multinational corporations. Estate,...

 

HTMLTreasury Issues Final Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
J. Clark Armitage, Kirsten Burmester, Arianna Caldwell, Scott D. Michel; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 20, 2016, previously published on December 19, 2016
On December 12th, the IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by obtaining a U.S. tax identification number (“TIN”) and in many circumstances, filing annual returns. Wealth advisors and their clients should...

 

HTMLVoluntary Disclosure Window Closing on Bitcoin Users
Mark E. Matthews, Scott D. Michel; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 7, 2016, previously published on December 2, 2016
On November 30, 2016, a federal court in San Francisco authorized the IRS to issue a “John Doe” summons to Coinbase, Inc., which operates a web-based global convertible digital currency wallet and platform and the largest platform in the U.S. for conversion of Bitcoin to dollars. The...

 

HTMLPossible Repeal of the Estate Tax in 2017
William D. Fournier, Beth Shapiro Kaufman, Anne J. O'Brien, Megan E. Wernke; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 6, 2016, previously published on December 5, 2016
The election of Donald Trump as the next President, along with continued Republican party control of both the House and the Senate, could signal that 2017 will be the year that the estate tax is repealed. This confluence of events significantly elevates the possibility of success for tax reform,...

 

Adobe PDFTax Plans Compared (December 2016) Individual Income Tax
Jonathan S. Brenner, Beth Shapiro Kaufman, Anne J. O'Brien; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 6, 2016, previously published on December 5, 2016
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes current law, President-Elect Trump’s proposal, and Speaker of the House Paul Ryan’s proposal on key individual income tax provisions relevant to high-net-worth individuals.

 

HTMLOffice of Government Ethics Revises Executive Branch Gift Rules
Bryson B. Morgan, Trevor Potter, Matthew T. Sanderson; Caplin & Drysdale, Chartered;
Legal Alert/Article
November 23, 2016, previously published on November 18, 2016
Effective January 1, 2017, the Office of Government Ethics (OGE) is revising the gift rules applicable to executive branch employees. The revisions were prompted by the Ethics in Government Act of 1978, which requires OGE to periodically update its regulations. For the most part, the revisions are...

 

HTMLCaptive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
Mark D. Allison, Rachel Leigh Partain, Christopher S. Rizek, Charles M. Ruchelman; Caplin & Drysdale, Chartered;
Legal Alert/Article
November 9, 2016, previously published on November 3, 2016
On November 1, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-66 identifying certain transactions relating to small captive insurance companies as a “transaction of interest.” Prior to this notice, the IRS had identified certain small captives as amongst its...

 


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