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Michael R. Miles Document Search Results (5) Sort by:  | A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss “Supersecret Rule”
Robert S. Chase, Reginald J. Clark, Michael R. Miles, William R. Pauls, William "Wes" E. Sheumaker; Sutherland Asbill & Brennan LLP;
Legal Alert/Article April 19, 2012, previously published on April 17, 2012 Nearly a year after issuing proposed regulations that aimed to modify the so-called “supersecret rule” of Treas. Reg. § 1.267(f)-1(c)(1)(iv) (the Proposed Regulations), Treasury and the Internal Revenue Service (the IRS) issued final regulations amending that rule on April 13, 2012...
| | IRS Issues Interim Guidance on the Federal Income Tax Treatment of Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature
Thomas A. Gick, James V. Heffernan, Michael R. Miles, William R. Pauls, W. Mark Smith, William J. Walderman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article August 17, 2011, previously published on August 16, 2011 On August 11, 2011, the Internal Revenue Service (the IRS) released interim guidance - Notice 2011-68 (the Notice) - addressing the application of certain changes to the federal income tax rules governing qualified long-term care (QLTC) insurance, annuity, and life insurance contracts....
| | "SRLY? You Can’t Be Serious.” “I Am Serious...and Don’t Call Me SRLY.” The IRS Issues Helpful Guidance on the Application of the SRLY Register Rules to Dual Consolidated Losses
Michael R. Miles, William R. Pauls; Sutherland Asbill & Brennan LLP;
Legal Alert/Article August 16, 2011, previously published on August 11, 2011 On August 5, 2011, the Internal Revenue Service (the IRS) issued a generic legal advice - AM 2011-002 (the Chief Counsel Memo) - explaining how the separate return limitation year (SRLY) rules apply to the computation of consolidated taxable income for an affiliated group with a dual consolidated...
| | It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53
Robert S. Chase, Dwaune L. Dupree, Michael R. Miles, William R. Pauls, Carol P. Tello; Sutherland Asbill & Brennan LLP;
Legal Alert/Article July 21, 2011, previously published on July 18, 2011 On July 14, 2011, Treasury and the Internal Revenue Service (IRS) released Notice 2011-53 (the Notice), which provides transition rules for implementation of the Foreign Account Tax Compliance Act (FATCA). Although the statutory effective date of the FATCA provisions is January 1, 2013, the...
| | IRS Modifies Guidance on Partial Exchanges of Annuity Contracts
Thomas A. Gick, Michael R. Miles, William R. Pauls, W. Mark Smith, William J. Walderman; Sutherland Asbill & Brennan LLP;
Legal Alert/Article July 5, 2011, previously published on June 30, 2011 On June 28, 2011, the Internal Revenue Service (IRS) issued Rev. Proc. 2011-38, which sets forth modified guidance with respect to the federal income tax treatment of “partial exchanges” of annuity contracts under sections 72 and 1035 of the Internal Revenue Code. In brief, Rev. Proc....
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