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Don’t Forget Ruling Guidelines

August 3, 2020 By Jasper L. (Jack) Cummings, Jr.

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 issue”Don’t assume there isn’t an IRS ruling guideline Read the full advisory here. [...]Read more

Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed

August 15, 2019 By Edward Tanenbaum and Heather Ripley

Our International Tax Group highlights new guidance on fundamental issues and points out a few sources of potential headache for taxpayers in response to the IRS and Treasury proposing the most significant regulations on passive foreign investment companies (PFICs) in nearly 30 years.

Clarifications for the Income and Asset Tests
Updates to the PFIC exceptions and look-through rules
PFIC stock attribution

Read the full advisory here. [...]Read more

Book Value Sales

December 1, 2017 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group explores how affiliates selling property to each other at book value could cause more problems than it solves.

Book value
Fair market value
The tax consequences

Read the full advisory here.

Federal Tax Advisory: Stock Dividend Foot Faults

January 3, 2017 By Jasper L. (Jack) Cummings, Jr.

Beware of the unexpected application of Section 305 to your stock distributions. Our Federal Tax Group serves up examples of useful tools to use.

Read the full advisory by clicking here.