The Treasury is open for business to change tax rules to ease your compliance burdens. Our Federal Tax Group points out a few regulations that could use some updating.
Reduce red tape
Regulations can ease the burden
What's on your list?
Read the full advisory here. [...]Read more
On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some alterations, these regulations deliver on guidance announced in Notice 2015-54, released in August 2015 (see our prior coverage of Notice 2015-54 here). The regulations incorporate a number of taxpayer-friendly updates in response to comments on the Notice. The prospect of further direction in this area, however, including guidance under Sections 482 and 6662 as described in the [...]Read more
There are still many questions about the meaning of the Treasury’s new regulations applying Section 355(e) to predecessors and successors. Our Federal Tax Group examines the answers we do have and what they mean for practitioners.
A recent Tax Court case shows the government’s willingness and ability to attack financing arrangements that do not reflect arm’s-length debt standards, even without the forthcoming Section 385 regulations. Our International Tax Group analyzes that case and reviews the IRS’s decision to stop treating some FATCA intergovernmental agreements as “in effect.”