A Delaware court quashed a subpoena aimed at an unclaimed property holder, but the victory may be short-lived. Our Unclaimed Property Team explores the latest court decision addressing a subpoena for records dating back to the 1990s. The subpoena … [Continue reading] about Pushing Beyond the Limit: Examining the Scope of Subpoenas Issued During Unclaimed Property Audits
Final FDII Regulations Released
Talk about a summer beach read... The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you. The Section 250 deduction … [Continue reading] about Final FDII Regulations Released
Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies
Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums. Split-dollar life insurance loans became even more beneficial after the TCJA … [Continue reading] about Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies
State-Sponsored Liability Limitation Funds
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 … [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