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1
IRS Issues The Opportunity Zone Regulations; The Race Is On
On October 19, 2018, the U.S. Department of Treasury and the Internal Revenue Service released the first set of the proposed regulations.
United States
21 Nov 2018
2
Newly Proposed US Tax Regulations Open Possibility Of Full Credit Support From Foreign Subsidiaries
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code.
United States
21 Nov 2018
3
IRS Releases Much-Anticipated Proposed Regulations Clarifying Hardship Distribution Rules
The IRS recently released Proposed Regulations that provide much-anticipated guidance with regard to recent hardship distribution changes, which resulted due to:
United States
21 Nov 2018
4
IRS Paves The Way For Lenders To Obtain Guarantees And Collateral From (And 100% Stock Pledges Of) Foreign Subsidiaries
Absent the applicability of the proposed regulations, such credit support generally would result in a taxable "deemed dividend" to the U.S. parent corporation borrower.
United States
20 Nov 2018
5
NBAA Comments On IRS Notice Regarding Business Meals
The National Business Aviation Association (NBAA) on Nov. 5, 2018, filed the attached comments with the Internal Revenue Service (IRS) regarding IRS Notice 2018-76...
United States
20 Nov 2018
6
New York Minimum Wage And Exempt Status Salaries Set To Increase Again, But Wage Deduction Rules May Expire
As they have each year since 2016, the minimum wage and exempt salary threshold will increase for New York employers effective December 31, 2018, with large employers in New York City being the first to hit the $15...
United States
16 Nov 2018
7
IRS Releases Proposed Hardship Distribution Regulations
Hopefully still in time for 2019 plan design discussions, on November 9, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued a Notice of Proposed Rulemaking to amend IRS regulations related to hardship distributions from 401(k) and 403(b) plans
United States
16 Nov 2018
8
Impact Of Proposed Regulations Under Section 956 On Lending Arrangements Involving U.S. Corporate Borrowers
Impact Of Proposed Regulations Under Section 956 On Lending Arrangements Involving U.S. Corporate Borrowers
United States
16 Nov 2018
9
Pennsylvania Supreme Court: Royalty Payments Not Subject To Sales And Use Tax
On October 25, 2018, in Downs Racing, LP v. Commonwealth, a unanimous Pennsylvania Supreme Court partially reversed the Commonwealth Court and held that royalty fees for intellectual property are not subject to sales...
United States
16 Nov 2018
10
New Guidance For Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open To Additional Guidance
The overall tenor of the proposed regulations is economic flexibility, and to that end, the proposed regulations are helpful to investors.
United States
16 Nov 2018
11
Formation: C-Corporation vs. LLC For Your Startup – Which Should I Choose?
In short, form an LLC if you're putting up a lot of your own capital or not seeking Venture Capital (VC) financing. Otherwise, save yourself time, aggravation, and money and form a C-Corp.
United States
16 Nov 2018
12
Additional Credit Support: How Changes To The ‘Deemed Dividend' Tax Regime Should Shape Your Thinking On Financing/Collateral Arrangements
On October 31, 2018, the Department of the Treasury and the Internal Revenue Service ("IRS")
United States
16 Nov 2018
13
Proposed Regulations Would Permit Employers To Reimburse An Employee's Premium Costs For A Health Insurance Policy Purchased In The Individual Market
Takeaway Message: Except in limited circumstances, current regulatory guidance prohibits an employer from maintaining a health reimbursement arrangement (HRA) ...
United States
15 Nov 2018
14
Hunton Insurance Recovery Blog: Georgia Court Of Appeals Holds That Policyholder Can "Stack" The Limits Of Each Primary Policy After Asbestos Claim
A Georgia Court of Appeals judge recently ruled that Scapa Dryer Fabrics was entitled to $17.4 million worth of primary coverage from National Union Fire Insurance Company of Pittsburgh...
United States
15 Nov 2018
15
Real Property, Financial Services & Title Insurance Update
Imputation of Implied Actual Notice: the fact that an unrelated purchaser of property was aware that seller was being sued on an unsecured indebtedness did not create a legal duty...
United States
15 Nov 2018
16
Treasury And IRS Issue Eagerly-Awaited Guidance On Hardship Distributions – With A Few Surprises
Last Friday, the IRS issued eagerly-awaited proposed regulations regarding hardship distributions under section 401(k) and 403(b) plans (the "Proposed Regulations").
United States
15 Nov 2018
17
Capitol Hill Healthcare Update - November 12, 2018
Below is this week's "Capitol Hill Healthcare Update," which is posted on Mondays when Congress is in session.
United States
15 Nov 2018
18
Tax Compliance Stakes Raised For Cryptocurrency Issues
At the International Tax Symposium held in Houston on Nov. 8 and 9 by the State Bar of Texas Tax Section, Daniel N. Price of the IRS Office of Chief Counsel reportedly said the IRS is not contemplating a separate disclosure program related to offshore cryptocurrency reporting.
United States
15 Nov 2018
19
Alimony Is No Longer Deductible By Taxpayer
For individuals who must pay alimony, not being able to deduct alimony payments can be a substantial and expensive change and may lead to an even more contentious divorce.
United States
15 Nov 2018
20
C-Suite Compensation Center Blog: ISOs: No Item Of Adjustment For AMT Purposes If Exercise And Sell Within Same Calendar Year
Did you exercise (or are planning to exercise) an incentive stock option ("ISO") during calendar year 2018?
United States
15 Nov 2018
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