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|2016 Year-End Estate and Tax Planning Summary|
Gregory M. Winters; Burke, Warren, MacKay & Serritella, P.C.;
December 22, 2016, previously published on December 2, 2016Few people predicted that Donald Trump would win the presidency and fewer still predicted that the Republican Party would control both houses of Congress along with the White House. While 2016 did not see the enactment of a great deal of tax legislation, 2017 and 2018 could see significant changes...
|Court Adopts Majority View in Sanctioning Bankruptcy Trustee’s Use of Tax Code Look-Back Period in Avoidance Actions|
Mark G. Douglas, Amanda A. Parra Criste; Jones Day;
December 22, 2016, previously published on November/December 2016The ability of a bankruptcy trustee or chapter 11 debtor-in-possession ("DIP") to avoid fraudulent or preferential transfers is an important tool promoting the bankruptcy policy of equality of distribution among creditors. One limitation on this avoidance power is the statutory...
|IRS Further Updates Beginning of Construction Guidance for Renewable Energy Tax Credits|
Dorothy Black Franzoni, Bradley M. Seltzer, Amish M. Shah, Wes Sheumaker, Ram C. Sunkara; Sutherland Asbill & Brennan LLP;
December 21, 2016, previously published on December 20, 2016On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-04, which updates prior guidance regarding the beginning of construction requirement for renewable energy tax credits under IRC sections 45 and 48.1
|Christmas Comes Early: IRS Provides Additional Year of Relief for Taxpayers Seeking to Implement Tangible Property Rules|
Ellen McElroy, Michael D. Resnick, Bradley M. Seltzer, Amish M. Shah, H. Karl Zeswitz; Sutherland Asbill & Brennan LLP;
December 21, 2016, previously published on December 21, 2016On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations (often referred to as the repair regulations) and certain other related...
|Tax Plans Compared (December 2016) Corporate Tax|
Mark D. Allison, Peter A. Barnes, Jonathan S. Brenner, Kirsten Burmester, Richard W. Skillman; Caplin & Drysdale, Chartered;
December 20, 2016, previously published on December 16, 2016It 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,...
|Treasury 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;
December 20, 2016, previously published on December 19, 2016On 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...
|Bottom Dollar Guarantees - It Appears That The Good Times Are Over For Good|
Douglas Turner Coats; Gordon Feinblatt LLC;
December 19, 2016, previously published on October 26, 2016The Treasury Department and the Internal Revenue Service (the “Service”) have recently issued temporary regulations that substantially reduce the ability of partners to allocate partnership liabilities among themselves by effectively eliminating what once was a common technique.
|Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities|
Robert S. Chase, Taylor M. Kiessig, Engin K. Nural, Carol P. Tello, H. Karl Zeswitz; Sutherland Asbill & Brennan LLP;
December 16, 2016, previously published on December 15, 2016Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) proposed and, on December 12, finalized...
|Tips for Jump-Starting Year-End Tax Planning for Individuals and Businesses|
Duane Morris LLP;
December 12, 2016, previously published on October 5, 2016With carefree summer days behind us and the arrival of fall, now may be a good time to jump-start implementation of tax-planning strategies available to you through the end of this year to potentially minimize your tax burden.
|Yellow Light Again - IRS Extends ACA Deadline to Furnish Forms|
Jim Hamilton; Bose McKinney Evans LLP;
December 12, 2016, previously published on November 20, 2016On November 18, 2016, the IRS extended the due date for employers to furnish 2016 Form 1095-B and Form 1095-C to individuals from January 31, 2017 until March 2, 2017. The IRS stated that the extension is appropriate because a substantial number of employers need additional time to gather and...