Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s ...
More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). 1 The Regulations ended decades of battles between ...
In temporary and proposed regulations issued earlier this month, the Treasury Department clarified the self-employment tax treatment for partners of a partnership that own a disregarded entity. Let me ...
The Internal Revenue Service and the Treasury Department issued a notice Wednesday saying they intend to issue proposed regulations withdrawing the disregarded payment loss rules for multinational ...
LLCs changing from partnership tax treatment to corporation or vice-versa may encounter issues including gain recognition.
In the decade since the “check-the-box” (CTB) regulations took effect, tax and business planners have taken advantage of their flexibility to structure a wide variety of transactions. Perhaps the most ...
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The IRS issued temporary regulations intended to halt the practice some partnerships have adopted of treating partners as employees of a disregarded entity owned by the partnership so they can be ...
We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...
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