Amendment to NYS Tax Law Affects Recording of Deeds for LLCs

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New York’s new real estate transfer tax recording requirements for LLCs raise questions on whether the scope and complexity of the changes can be enforced or noncompliance monitored. Our State & Local Tax Group explores: Disclosing all LLC members Who is a “natural person”? Compliance and confidentiality concerns Read the full advisory here. [...]Read more

Selling Contracts

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If you think about it, franchises aren’t just fast food restaurants and auto parts stores within a specified area. Our Federal Tax Group reveals how nearly any contract to buy or sell goods or services can lead to favorable capital-gains treatment. Defining “franchise” under Section 1253 Examples of franchise contracts How limiting is the “specified area” requirement? Read the full advisory here. [...]Read more

Is the IRS “HODLing” Out on Us? IRS Issues Additional Cryptocurrency Guidance Addressing Hard Forks, Soft Forks, and Airdrops

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The IRS provided some much-needed guidance on protocol changes to blockchain. Our International Tax Group breaks it down.

  • What the forking wallet?
  • Two scenarios for hard forks
  • What about airdrops?

Read the full advisory here.

Do You Need to Send an Annual Notice to Plan Participants?

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Check out our review of the multiple year-end notices that defined contribution plans must issue to participants.

  • 2020 retirement plan limits
  • Notice content and deadlines
  • Practice pointers

Read the full advisory here.

Qualified Retirement Plan Considerations and 2019 Year-End Action Items

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Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2019 IRS year-end amendments and offers year-end action items. Discretionary amendments Changes to hardship withdrawals Adjustment to the determination letter program Read the full advisory here. [...]Read more

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

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The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code. Downward attribution beyond Subpart F, GILTI, and Section 965 Silence on the portfolio interest exemption Safe harbors and eased reporting requirements Read the full advisory here. [...]Read more

A Qui Tam Win for Holders, New Federal Common-Law Ruling, JPMorgan Appeals, and a Possible California Amnesty Program

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Our Unclaimed Property Team highlights several recent rulings – both federal and state from across the country – and a new California law that could have broad implications for holders. Qui tam rulings in Delaware and New York A fight for removal from state to federal court A possible California amnesty program Read the full advisory here. [...]Read more

Final Hardship Distribution Rules Are Here: Does Your 401(k) or 403(b) Plan Comply?

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Our Employee Benefits & Executive Compensation Group examines the numerous changes – mandatory and permissible – plan sponsors can make to their 401(k) or 403(b) plans in light of new regulations for hardship distributions. When do you need to amend your plan? What are the mandatory and permissible changes? What next steps should you take? Read the full advisory here. [...]Read more

NOL Regulations Proposed

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Our Federal Tax Group covers the potential changes to recognizing built-in income in reaction to Treasury proposing new Section 382 regulations with a built-in feature that many will think is a bug. Using the Section 382 deduction limitation Using Section 338 for built-in gains Using the 1374 method for built-in losses Read the full advisory here. [...]Read more