Searching Content indexed under Income Tax by WilmerHale ordered by Published Date Descending.
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Revaluations In Upper-Tier Partnerships — An Alternative Approach
Section 704(c)(1)(A) is a seemingly modest provision.
United States
5 Jul 2019
Tax Act: Key Issues For Pass-Through Entities, Including The Carried Interest
General. The new Section 199A generally provides that for taxable years beginning after December 31, 2017, and before December 31, 2025, taxpayers other than corporations ...
United States
15 Jan 2018
Tax Act: New Opportunity To Defer Income From Certain Private Company Equity Grants
The new Section 83(i) of the tax code, enacted as part of the Tax Act, allows certain private company employees to elect to defer, solely for income tax purposes and for a period of up to five years ...
United States
15 Jan 2018
Tax Cuts And Jobs Act Summary
On December 22, 2017, President Trump signed sweeping tax reform legislation (H.R. 1) into law. The new law, commonly known as the Tax Cuts and Jobs Act (the "Tax Act"), makes significant changes ...
United States
15 Jan 2018
IRS Issues Guidance On The Applicability Of Section 162(m) To CFO Compensation
The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code and applied the limitation to CFOs of certain smaller public companies.
United States
23 Nov 2015
Tax Time Alert: Key Things To Know About Founders Preferred Stock
As you gather and review tax papers for your return, be sure to inform your accountant if you hold founders’ preferred stock, or if you sold a block of it in 2014.
United States
13 Apr 2015
Final Section 162(m) Regulations Clarify Transition Rules For Newly Public Companies And The Per Participant Limit Requirement
Following the issuance of proposed regulations in June 2011, the Internal Revenue Service issued final regulations on March 30, 2015 clarifying certain exceptions to the compensation deduction limitation imposed by Section 162(m) of the Internal Revenue Code.
United States
2 Apr 2015
Whose Refund? Eleventh Circuit Muddies The Law On Ownership Of Bank Tax Refunds In Bankruptcy
A new decision by the Eleventh Circuit has complicated the question of whether a tax refund is owned by a bank holding company in its bankruptcy, or by the holding company’s operating bank subsidiary in its receivership.
United States
9 Sep 2013
IRS Extends Timelines Under FATCA And Provides Further Guidance With Regards To Intergovernmental Agreements
On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43 (the Notice), which modifies the timelines for the implementation of certain requirements under Sections 1471 through 1474 of the Internal Revenue Code (commonly referred to as the Foreign Account Tax Compliance Act or FATCA).
United States
15 Jul 2013
Equity Incentives: Interesting Developments In The UK For 2013
EMI options are intended to help smaller companies with growth potential, and the major tax advantages of EMI have always been no UK income tax at grant and no UK income tax at exercise if the exercise price is set at market value.
United States
21 May 2013
Investments In Qualified Small Business Stock In 2012 And 2013
The American Taxpayer Relief Act of 2012 extends—and makes retroactive—the ability of non-corporate investors to exclude from federal taxable income 100% of the eligible gain realized from the sale of "qualified small business stock".
United States
9 Jan 2013
FBAR Deadline Is June 29, 2012; IRS Form 8938 May Also Be Required
The June 29, 2012 filing deadline for the 2011 Report of Foreign Bank and Financial Accounts (FBAR) is fast approaching, except for those covered by the limited exception described below.
United States
11 Jun 2012
Investing In Qualified Small Business Stock In 2011
Since its enactment in 1993, Section 1202 of the Internal Revenue Code has provided non-corporate investors with the ability to exclude from federal taxable income up to 50% of the gain realized from the sale of "qualified small business stock" (QSB Stock) held for more than five years.
27 Oct 2011
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