LexisNexis® Legal Newsroom
Neil Aragones
Covered Asset Acquisitions Regulations Examined

Proposed and temporary regulations under IRC Section 901(m) affect covered asset acquisitions, which are transactions that are generally treated as asset acquisitions for U.S. income tax purposes and that either are treated as stock acquisitions or are...

Susan Calistri Boesger
Qualified Terminable Interest Property Trust Basics

The Qualified Terminable Interest Property (QTIP) Trust was a creation of ERTA-1981 pursuant to IRC § 2056(b)(7) which qualifies for the marital deduction, even if the surviving spouse is not given a general power of appointment during life or at...

LexisNexis Tax Law Community Staff
Classifying Debt and Equity

by Shahzad A. Malik J.D. LL.M and Ryan C. Gaglio J.D. * In General "There is no dearth of cases in this province of tax law. So large is their number and disparate their facts, that for every parallel found, a qualification hides in the thicket...

Neil Aragones
New Regs on Earnings Strippings Transactions

On October 13, 2016, the Treasury and IRS issued regulations [T.D. 9790 (Oct. 13, 2016)] finalizing and revising proposed regulations issued earlier in the year that targeted post-inversion earnings strippings transactions, which are certain related-party...

LexisNexis Tax Law Community Staff
Global Positioning of IP: State Research and Development Credits

by William H. Byrnes and Marvin Petry * Federal and state research and development (R&D) tax credits are powerful yet underutilized opportunities that can make a big difference in operating performance and cash flow for companies that rely on performing...

Elaine Hightower Gagliardi
IRC Section 2704 Proposed Regulations

Treasury published long-awaited proposed revisions to the existing I.R.C. Section 2704 regulations on August 4, 2016. 81 Fed. Reg. 51413 . If published as final regulations in current form, the revisions will inhibit transfers of closely-held business...