Holders and custodians of retirement assets, such as 401(k)s, IRAs, and Roth IRAs, face numerous challenges associated with the potential escheatment of these tax-deferred retirement assets. In this installment of “UP Ahead” for Tax Notes State, unclaimed property partners Kendall Houghton and Matt Hedstrom discuss the scope of federal preemption in this arena and the concept of voluntary escheatment of tax-deferred retirement assets. Read the full article here. … [Continue reading] about Special Challenges with Escheating Tax-Deferred Retirement Assets
Federal Tax Advisory: Disaster Losses
With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019. An introduction to Section 165(i)The expansion of … [Continue reading] about Federal Tax Advisory: Disaster Losses
Proposed Treasury Regulations Clarify UBTI “Silo” Rule
Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that … [Continue reading] about Proposed Treasury Regulations Clarify UBTI “Silo” Rule
Tax Determinations in Bankruptcy
For the May federal tax advisory, we considers the unclear tax powers of the bankruptcy courts and how the IRS won’t take any determinations too kindly. Prepetition tax claimsThe IRS’s constitutional and statutory defensesBankruptcy … [Continue reading] about Tax Determinations in Bankruptcy
Risky Business – Allocating Losses When Your Supply Chain Is Disrupted
Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now … [Continue reading] about Risky Business – Allocating Losses When Your Supply Chain Is Disrupted