Holders of tax-deferred retirement assets must weigh and balance significant owner-facing risks against a clear set of state-facing compliance requirements and risks. In this installment of “UP Ahead” for Tax Notes State, unclaimed property partners … [Continue reading] about Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2
Don’t Forget Ruling Guidelines
Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant … [Continue reading] about Don’t Forget Ruling Guidelines
Pushing Beyond the Limit: Examining the Scope of Subpoenas Issued During Unclaimed Property Audits
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