Tax Change Planning

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With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking. Tax Reform Act of 1986 Payment of dividends and stock buybacks Less advantageous structures Read the full advisory here. [...]Read more

Dealing with Disaster: Issues and Relief for Employee Benefits Plans

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In the wake of the widespread destruction caused by Hurricanes Harvey and Irma, federal agencies have offered employers and plan sponsors relief from some deadlines and other issues. Our Employee Benefits & Executive Compensation Group discusses common issues and offers a high-level overview of the types of relief that may be available. Health plan coverage and retirement plan issues Tax filing deadlines and leave donation programs Additional federal resources Read the full advisory here. [...]Read more

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

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At the end of the month, dozens of countries will begin exchanging information under the OECD’s Common Reporting Standard as “early adopters.” Our International Tax Group examines the CRS and its relation to FATCA. How does the CRS work? What are the reporting requirements? How will the CRS impact U.S. taxpayers? Read the full advisory here.  [...]Read more

Lawsuits Are Focused on Wellness Program Compliance. Are You?

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Wellness programs are a win-win for everybody – until administrators run afoul of ambiguous rules and regulations. Our Employee Benefits & Executive Compensation Group analyzes two recent lawsuits that could impact program design and tobacco surcharges. AARP v. EEOC Acosta v. Macy’s The implications Read the full advisory here.  [...]Read more

Federal Tax ADVISORY: Dual-Class Stock Blessing for Spin

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A new Letter Ruling from the IRS brings concerns for corporations looking at a spinoff. Our Federal Tax Group breaks down the guidelines and what they mean.

  • Dual-class structure
  • Debt
  • Delayed transfers

Read the full advisory here.

Tax Policy & Regulation ADVISORY: If Republicans Agree on 80% of Tax Reform, What’s the Other 20%?

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Our Tax Policy & Regulation Team explores the uneven terrain unfolding in the tax reform debates, from the debt limit to the deficit to reconciliation. Non-tax issues may impact tax reform One of the most fundamental issues for tax reform Adding to the uncertainty Read the full advisory here. [...]Read more

Unclaimed Property ADVISORY: Delaware’s Escheats Law Faces Due Process Challenge

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Our Unclaimed Property Team delves into the Third Circuit decision that gives Plains’s due process claim its day in court and could give holders a leg up on Delaware’s Escheats Law. The district court dismisses on all counts Third Circuit allows due process claim The implications Read the full advisory here. [...]Read more

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

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The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be. Public and judicial scrutiny Standard of review Where do we go from here? Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Partial Worthlessness

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Don’t overlook claiming a deduction for partial worthlessness. Our Federal Tax Group provides a refresher on this useful tool.

  • Cross-border or brother-sister debt
  • A hard pill to swallow
  • Ordinary loss

Read the full advisory here.

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

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Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more