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By McDermott Will & Emery on Jun 18, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Here’s what happened in the world of IRS guidance for the week June 11 – 15, 2018. June 11, 2018: The IRS issued Notice 2018-55 describing potential proposed regulations that would offer relief to some private colleges and universities by providing a stepped-up basis rule that could reduce the amount of gain subject to a...
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Weekly IRS Round-up: June 4 – 8
By McDermott Will & Emery on Jun 11, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
In order to continue to keep our readers informed on tax matters, we will be rolling out weekly posts on significant Internal Revenue Service (IRS) guidance and relevant tax cases. This post marks our first round-up of IRS guidance for the week June 4 – 8, 2018. June 4, 2018: The IRS issued 3 new...
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A 360-Degree View: April and May 2018
By McDermott Will & Emery on May 4, 2018
Posted In Uncategorized
Wrapping Up April – and Looking Forward to May Top April Posts You May Have Missed President Trump Announces Intent to Nominate Emin Toro to Tax Court IRS Releases Practice Unit on Statutes of Limitation National Taxpayer Advocate Reminds Congress of IRS Deficiencies Tax Controversy Activities This Week May 1, 2018: Elizabeth Erickson is on...
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Tax Takes Video: Issues Facing CFCs
By McDermott Will & Emery, Jay M. Singer and Timothy S. Shuman on Apr 11, 2018
Posted In Tax Reform, Uncategorized
Partners Alexander Lee, Tim Shuman, Britt Haxton and Jay Singer discuss novel concerns facing CFCs in light of tax reform.
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A 360-Degree View: March and April 2018
By McDermott Will & Emery on Apr 5, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Wrapping Up March – and Looking Forward to April Top March Posts You May Have Missed White House Intends to Nominate Michael J. Desmond to High-Level Roles in the IRS and the Department of Treasury The IRS May Be Coming for Your Bitcoins Tax Court Judicial Conference This Week in Chicago Upcoming Tax Controversy Activities...
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The Fifth Circuit Puts an End to the Madness with its March Opinion
By McDermott Will & Emery and McDermott Will & Emery on Mar 21, 2018
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
We have all heard the famous quote about doing the same thing over and over again and expecting different results. The Court of Appeals for the Fifth Circuit applied this concept in its March 8 opinion in Annamalai v. Comm’r, No. 17-60255. There, the issue was whether the taxpayers could extend into perpetuity the 90-day...
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Tax Takes Video: Should I Convert My Entity?
By McDermott Will & Emery and Daniel Zucker on Mar 19, 2018
Posted In Tax Reform, Uncategorized
In the below Tax Takes Video, Dan Zucker and Alexander Lee discuss the pros and cons of converting your entity from an S corp to a C corp.
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US Tax Reform: Potential Role of the APA Program
By McDermott Will & Emery and Kristina Novak on Jan 31, 2018
Posted In Tax Reform, Transfer Pricing Resource, Uncategorized
US tax reform finally occurred in 2017 with what was formerly referred to as the Tax Cuts and Jobs Act of 2017 (the Act). The headline from a corporate standpoint is reduction in the maximum rate from 35 percent to 21 percent beginning in 2018. In the international context, the Act: (i) embraces a territorial...
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Treasury Moves Forward on Proposing Withdrawal of Regulations
By McDermott Will & Emery and McDermott Will & Emery on Jan 26, 2018
Posted In IRS Guidance, Uncategorized
As we previously discussed, the US Department of the Treasury (Treasury) announced a plan in October 2017 to repeal more than 200 regulations. The plan appears is moving forward based on remarks by Acting Chief Counsel William M. Paul earlier this week at the New York State Bar Association Section meeting that the Internal Revenue...
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Tax Takes: Financing Issues Under The Tax Act
By McDermott Will & Emery on Jan 9, 2018
Posted In Tax Reform, Uncategorized
Private equity sponsors and their lenders are particularly impacted by two key changes to business tax provisions in the Tax Cuts and Jobs Act: the new limitation on deductibility of business interest expense and the temporary increase in the amount of capital expenditures that may be currently expensed. In our latest Tax Takes video, Gary...
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