Sutherland Legal Alert: IRS Releases Advance Draft of Proposed Regulations on Governmental Plans

LEGAL ALERT By Carol Weiser The Internal Revenue Service (IRS) has issued an advance notice of proposed rulemaking to release rules being considered for determining governmental plan status for qualified retirement plans under Internal Revenue Code (Code) section 414(d). The guidance includes draft...

Sutherland Legal Alert: IRS Releases Advance Draft of Proposed Regulations on Governmental Plans

LEGAL ALERT By Carol Weiser The Internal Revenue Service (IRS) has issued an advance notice of proposed rulemaking to release rules being considered for determining governmental plan status for qualified retirement plans under Internal Revenue Code (Code) section 414(d). The guidance includes draft...

IRS Issues Proposed Rules Clarifying Alternate Valuation Rules

The executor can elect to value property in the decedent's estate at the alternate valuation date in an effort to reduce the estate's tax liability. IRC § 2032 . The alternate valuation election is provided solely to mitigate the hardship on an estate due to declining market values. A voluntary...

IRS Issues Proposed Rules Clarifying Alternate Valuation Rules

The executor can elect to value property in the decedent's estate at the alternate valuation date in an effort to reduce the estate's tax liability. IRC § 2032 . The alternate valuation election is provided solely to mitigate the hardship on an estate due to declining market values. A voluntary...

IRS Issues Final "Hot Stock" Regulations

The IRS recently issued final regulations regarding the distribution of stock of a controlled corporation acquired in a transaction under IRC Section 355(a)(3)(B) . TD 9548, 76 FR 65110 . The final regulations adopt the substantive rules of the temporary regulations without change. TD 9435, 73 FR 75946...

IRS Issues Final "Hot Stock" Regulations

The IRS recently issued final regulations regarding the distribution of stock of a controlled corporation acquired in a transaction under IRC Section 355(a)(3)(B) . TD 9548, 76 FR 65110 . The final regulations adopt the substantive rules of the temporary regulations without change. TD 9435, 73 FR 75946...

Penalties on Exempt Entities & Managers for Prohibited Tax Shelters

By Andrew W. Singer, Esq.* In addition to imposing disclosure obligations on participants in and material advisors to reportable transactions and penalties for violation of those obligations, the Code also imposes penalties in the form of excise taxes on tax-exempt entities that act as accommodation...

Funding the Family Foundation: Qualified Appreciated Stock

by Joy S. MacIntyre , Morrison & Foerster LLP In an earlier post we described some of the tax benefits - and challenges - associated with donating corporate securities to a family foundation or other private foundation. On the right facts, the donor in such a case can claim a deduction equal to...

Funding the Family Foundation: Qualified Appreciated Stock

by Joy S. MacIntyre , Morrison & Foerster LLP In an earlier post we described some of the tax benefits - and challenges - associated with donating corporate securities to a family foundation or other private foundation. On the right facts, the donor in such a case can claim a deduction equal to...