Tax Law Community

Title	Views
1	Textron Inc. V. United States, 2010 U.S. LEXIS 4373 (U.S., May 24, 2010)	7257
2	The Even More Curious Case of Xilinx, Inc. v. Commissioner and the Future of Transfer Pricing	6805
3	James McElligott, of McGuireWoods, LLP, on Group Health Plan Failures, Enforcement of Sponsor Employer Reporting Requirements, and the Related Excise Tax Regime	6149

Issuing a Trust’s Promissory Note to Defer Payment of a Unitrust Amount Should Not Cause the Trust to Recognize Gain or Loss

By Danielle T. Zaragoza, Esq. , Morrison & Foerster LLP The basic concept of a unitrust is that a fixed percentage of the fair market value of a trust's assets, redetermined each year, is paid out to the "income" beneficiary, regardless of the availability

Published Tue, May 1 2012 7:58 AM by Morrison and Foerster LLP

Pepper Hamilton LLP Tax Update: Carried Interest Fairness Act of 2012 Retains Capital Gain on Enterprise Value

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP On February 14, 2012, Rep. Sander M. Levin (D-Mich.) again introduced legislation (H.R. 4016) to tax income from carried interests at ordinary rates. Taxing Carried Interests

Published Mon, Apr 30 2012 10:06 AM by Pepper Hamilton LLP

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses that rob the U.S

Published Mon, Apr 9 2012 7:00 AM by Pepper Hamilton LLP

Two Year Increase in Gift Tax Exclusion is Nearing Its End – The Window for Tax Savings Is Closing Quickly

By Genevieve M. Moore and Richard S. Kinyon , Morrison & Foerster LLP As reported in this space over the last several months, there has been unprecedented upheaval in the federal transfer tax world in the last few years. One element of this was the unexpected

Published Mon, Apr 2 2012 6:59 PM by Morrison and Foerster LLP

Sutherland Legal Alert: U.S. Tax Court Issues Opinion in Tigers Eye Regarding Golsen Rule and TEFRA Proceedings

By Tom Cullinan , Joe DePew , and Shane Lord , Sutherland Asbill & Brennan LLP We rarely send out Legal Alerts about the so-called "TEFRA" rules that govern partnership audits and litigation because so few people would read them. In Tigers Eye , however

Published Fri, Mar 16 2012 3:50 PM by Sutherland Asbill & Brennan LLP

Options For Clients Who Offer Retirement Benefits For Domestic Employees, From Morrison & Foerster

By Wendy M. Greenberg, Esq. , Morrison & Foerster LLP We have previously discussed in this space the possible tax traps related to clients' gifts and bequests to their employees. This article continues in that vein to provide some practical options specifically

Published Thu, Mar 1 2012 7:41 PM by Morrison and Foerster LLP

Sutherland Legal Alert: FinCEN Extends Due Date for Certain FBAR Filers

By Robb Chase and Amanda Pugh On February 14, 2012, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial Accounts

Published Thu, Mar 1 2012 1:24 PM by Sutherland Asbill & Brennan LLP

Morrison & Foerster LLP: Charities, S Corporations and UBIT: Why a Charitable Gift of S Corporation Stock May Not Be the Best Option

Not all charitable gifts are created equal, and a charity is not required to accept any and all donations of property, especially property that may be difficult to own or liquidate in furtherance of the charity's purpose. For instance, before a charity

Published Wed, Feb 1 2012 11:16 AM by Morrison and Foerster LLP

Pepper Hamilton LLP: IRS Provides Additional Guidance on Form W-2 Informational Reporting Requirements

By Michael A. Kadlec and Joseph F. Murphy On January 3, 2012, the Internal Revenue Service issued Notice 2012-9 (available at http://www.irs.gov/pub/irs-drop/n-12-09.pdf ), which restates and clarifies previously issued guidance on the requirement under

Published Tue, Jan 31 2012 6:54 AM by Pepper Hamilton LLP

Duane Morris LLP: New 2012 Offshore Voluntary Disclosure Program; Taxpayer Advocate Criticizes IRS "Bait & Switch"; Current Offshore Enforcement Initiatives

By Thomas W. Ostrander 2012 Offshore Voluntary Disclosure Program Announced by IRS: Details and Issues On January 9, 2012, the Internal Revenue Service (IRS) announced that it had reopened the Offshore Voluntary Disclosure Program (OVDP) following the

Published Wed, Jan 25 2012 8:58 AM by Duane Morris LLP

Sutherland Legal Alert: IRS Extends and Expands Relief, Seeks Comments on Puerto Rico Plans and Group Trusts

By Mark Smith and Jamey Medlin IRS Notice 2012-6 , to be published on January 17, 2012, extends and expands the transition relief provided under Rev. Rul. 2011-1 and Rev. Rul. 2008-40 for certain retirement plans that qualify under the Puerto Rico Internal

Published Fri, Jan 20 2012 3:45 PM by Sutherland Asbill & Brennan LLP

Pepper Hamilton LLP: Application of Interest Netting Rules to Consolidated Groups

By Todd B. Reinstein and Nicholas Metcalf As is widely known, taxpayers must pay interest on tax deficiencies and the IRS must pay interest on overpayments. 1 The interest rates charged by the IRS for deficiencies is not surprisingly higher than the interest

Published Thu, Jan 19 2012 2:04 PM by Pepper Hamilton LLP

Pepper Hamilton LLP: IRS Proposes Taxpayer-Friendly Changes to Section 382

By Annette M. Ahlers and Todd B. Reinstein Section 382 of the Internal Revenue Code generally requires a corporation to limit the amount of its income in future years that can be offset by historic losses (NOLs) once that corporation has undergone an

Published Thu, Jan 19 2012 1:57 PM by Pepper Hamilton LLP

Fulbright & Jaworski LLP: IRS Gives Taxpayers Third Bite At The Apple; Announces Third Offshore Voluntary Disclosure Program

By Jasper G. Taylor, III , Robert C. Morris and Zhusong Yang The IRS, in a news release dated January 9, 2012, IR-2012-5 , announced the reopening of its offshore voluntary disclosure program ("2012 Offshore Voluntary Disclosure Program") that allows

Published Fri, Jan 13 2012 3:51 PM by Fulbright and Jaworski L.L.P.

McDermott Will & Emery: Deadline Approaching for Filing New IRS Form 8955-SSA

By Natalie M. Nathanson , Stephen Pavlick PC and Adrienne Walker Porter New Internal Revenue Service (IRS) Form 8955-SSA (the Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits) replaces the Schedule SSA of

Published Fri, Jan 13 2012 3:41 PM by McDermott Will & Emery

Featured Content

You are not logged in. Please Login to add content to your community page

Visit Other Communities By

Latest Postings

Most Viewed Postings