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
Last week, our Federal Tax Group considered whether corporations that have engaged in spinoffs should be aggressive in deducting expenses.
Read the full advisory here.
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
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
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