Our Federal Tax Group examines an IRS letter ruling on a company’s ability to take advantage of Section 197 intangibles. What is a liability limitation fund, and how can a company receive payments?What “event” triggers payment?What advantage is gained? Read the full advisory here. … [Continue reading] about State-Sponsored Liability Limitation Funds
Who Says You Can’t Go Home? IRS Sends Care Package to Those Away from Home Due to COVID-19
Government-ordered travel restrictions have kept taxpayers far from home, but new IRS guidance provides some relief. Our International Tax Group translates the Revenue Procedures and FAQs into plain English. How noncitizens will be treated as … [Continue reading] about Who Says You Can’t Go Home? IRS Sends Care Package to Those Away from Home Due to COVID-19
Special Challenges with Escheating Tax-Deferred Retirement Assets
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, … [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