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Trending ..... Section 336(e) & Disposition of Subsidiary Stock ..... Marketplace Fairness Act ..... Tax Reform ..... FY 2014 Budget..... Final FATCA Regs ..... Fiscal Cliff (ATRA) ..... Historic Boardwalk Hall ..... Higher Medicare Taxes for Higher Earners ..... IRS Guidance on Personal Use of Corporate Aircraft ..... FATCA's Model Intergovernmental Agreements ..... Estate & Gift Tax Legislation ..... Penalty Framework For Offshore Accounts

Latest U.S. Tax Law News

McDermott Will & Emery: N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

May 22, 2013 Tax

Troutman Sanders: Top Ten Tips for Trustees and Trust Officers to Avoid Litigation for Breach of Duty

May 21, 2013 Wealth Management

Kilpatrick Townsend: Stock Sale with an Asset Basis Step Up: New Alternative to the Section 338 Election

May 21, 2013 Section 336(e) & Disposition of Subsidiary Stock

Home Concrete & Overstatement of Tax Basis

Akerman: Recent Supreme Court Decision in Home Concrete: A Victory For Taxpayers

Sutherland: U.S. Supreme Court Holds That Extended Six-Year Statute of Limitations Is Not Triggered by an Overstatement of Basis

Miller Chevalier: The Supreme Court's Home Concrete Decision May Limit Treasury's Ability to Use Regulations to Overturn Judicial Interpretations of Statutory Language

HIRE Act's Repeal of Bearer Bond Exception & IRS Guidance

Milbank: New IRS Guidance: "Bearer" Bonds May Now Be "Registered"

Paul Hastings: Recent IRS Guidance on Repeal of Bearer Bond Exception: Notice 2012-20

Sullivan & Cromwell: Foreign-Targeted Bearer Bonds: IRS Issues Transitional Guidance on the Upcoming “Bearer Bond” Repeal

IRS Guidance on Foreign Tax Credit "Splitter" Transactions

Covington & Burling: What’s New in the Technical Taxpayer and §909 Guidance

Baker & McKenzie: Internal Revenue Service Issues Temporary and Final Treasury Regulations on Foreign Tax Credit Splitters

SNR Denton: Guidance on Foreign Tax Credit "Splitter" Transactions and on a Taxpayer's Eligibility for the Foreign Tax Credit Published

Obama Administration's Framework for Business Tax Reform

Baker Hostetler: President Obama's Tax Reform Framework

Skadden: Obama Administration Releases Framework for Business Tax Reforms

Nixon Peabody: President Obama announces framework for business tax reform

FY2013 Budget & Greenbook

Duane Morris: Obama Administration's 2013 Budget Proposal Includes Key Changes to Income Tax and Transfer Tax Provisions

Troutman Sanders: The Administration’s FY 2013 Estate and Gift Tax Proposals

K&L Gates: The Devil Is in the Details: Treasury Releases “Green Book” of Obama Administration FY 2013 Tax Priorities

IRS Issues Regulations Re: Withholding of "Dividend Equivalents"

Willkie Farr & Gallagher: Dividend Equivalent Payments Proposed Regulations’ Effective Date Postponed One Year

Akin Gump: Treasury Extends Effective Date of Temporary Regulations on Dividend Equivalent Payments

Lowenstein Sandler: Treasury Takes Aim At Equity-Linked Instruments: Proposed Treasury Regulations Expand the Scope of Dividend Equivalent Payments Subject to U.S. Withholding Tax

New IRS Form 8937 For Reporting Corporate Actions Affecting Stock Tax Basis

Pepper Hamilton: Reporting of Organizational Actions Affecting Basis of Securities

Willkie Farr & Gallagher: Important Update: IRS Issues New Notice Relaxing Information Reporting Requirements For 2011 Corporate Actions

Paul Weiss: New U.S. Tax Reporting Due by January 17, 2012 for Corporations that Engaged in Certain Transactions in 2011

IRS Issues Rules Clarifying Tax Treatment of Partnership Debt for Equity Exchanges

Kaye Scholer: IRS Issues Final Regulations on Partnership Debt-for-Equity Exchanges

Day Pitney: IRS Issues Final Regulations on Treatment of Partnership Debt for Equity Exchanges

McDermott Will & Emery: Final Regulations on Partnership Debt-for-Equity Exchanges

Proposed IRS Rules Would Clarify Tax Treatment of U.S. Investments by Foreign Governments

Pepper Hamilton: Proposed Regulations Ease Sovereign Wealth Fund Investment into Private Equity Funds

Shearman & Sterling: Sovereign Immunity: A US and European View

Weil Gotshal: Proposed Guidance Under Section 892 Regarding Taxation of Foreign Governments on US Investment Income

FY2012 Budget & Greenbook

Edwards Angell: New Short Term FY 2011/ FY 2012 Budget/ Next Steps

Orrick: The Obama Administration’s Fiscal Year 2012 Revenue Proposals

Sullivan & Cromwell: President Obama’s Fiscal Year 2012 Revenue Proposals: Proposals Relating to International Taxation

Fulbright & Jaworski: Opportunities for Owners of Early Stage Businesses Under the 2010 Tax Relief Act

McDermott Will & Emery: Year-End Legislation Extends Key Provisions for Businesses, Provides 100 Percent Expensing for Certain Assets and Enacts New Foreign Procurement Excise Tax [Subpart F & Look-through rule]

Paul Hastings: Certain Exceptions to Subpart F Income Are Extended for Two Additional Years Under The Tax Relief Act of 2010

Mayo Foundation & Standard of Review for Tax Regulations

Greenberg Traurig: The 'Mayo' Decision's Problematic Tax Analysis

Baker Donelson: Medical Residents and Other Working Graduate Students may be Subject to Social Security Taxes [Mayo Foundation]

Latham & Watkins: Mayo Foundation — The Supreme Court Clarifies The Standard Of Review For Tax Regulations

Report of Foreign Bank and Financial Accounts (FBAR)

Willkie Farr & Gallagher: Treasury Department Extends FBAR Deadline Until June 30, 2014 For Certain Filers

Ropes & Gray: FBAR Filing Deadline Further Extended to June 30, 2014 for Certain Employees and Officers with Signature Authority Over Foreign Financial Accounts

Sullivan & Cromwell: Reporting Requirements for Foreign Financial Accounts: FinCEN Releases Notice Extending Deadline to June 30, 2014 for Certain Signature Authority Filers

Estate & Gift Tax Legislation

Holland & Knight: Estate Planning with Portability: Not a Panacea

Stroock: Federal Estate Tax Reform on the Horizon: President’s Newly Released 2014 Budget Proposals Would Roll Back the $5,000,000 Estate, Gift and GST Tax Exemptions to 2009 Levels...

McGuireWoods: Estate Tax Changes Past, Present and Future [Updated]

IRS Proposes to Expand the Definition of "Publicly Traded" Debt

Paul Hastings: Treasury Issues Proposed Regulations Expanding the Definition of Publicly Traded Property

Venable: New Regulations on Debt Instruments – They Give a Little and Take a Little

Cleary Gottlieb: Treasury and IRS Publish Proposed Tax Regulations Affecting Debt Exchanges and Restructurings

Foreign Account Tax Compliance Act of 2009 (FATCA)

Sutherland: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

Latham & Watkins: Preparing for FATCA Compliance: The First Step

SJBerwin: Jumping on the FATCA Bandwagon

Codification of Economic Substance Doctrine

Alston & Bird: Supreme Court to Review Economic Substance Case [United States v. Gary Woods]

Alston + Bird: IRS May Apply Economic Substance Doctrine to Securities Lending Transactions Entered to Avoid U.S. Withholding Tax

Alston + Bird: Economic Substance Doctrine Defense Plan

IRS's Penalty Framework For Offshore Accounts

Nixon Peabody: The door closes for "quiet disclosures"

Alston & Bird: The United States, Australia and the United Kingdom Gang Up on International Tax Evasion

Kelley Drye: Unprecedented Leak of Confidential Financial Information May Lead to Further Crackdown by Global Tax Authorities

Cancellation of Debt Income (CODI)

Dechert: Treatment of Excess Nonrecourse Partnership Debt and COD Income Under Section 108

Jones Day: Partial Debt Cancellations: Slicing Debt with Occam's Razor

Clifford Chance: The IRS Releases Temporary Regulations Regarding the Election to Defer Cancellation of Debt Income

Using Net Operating Losses (NOLs)

Pepper Hamilton: Bankruptcy PLR with NOL Preservation Result

Pepper Hamilton: New Chief Counsel Advice on Coordinated Acquisitions for Section 382 Purposes Raises Concerns

Pepper Hamilton: Section 382 Issues Raised in an Acquisition of a Loss Corporation by a Private Equity Group

Reporting of Uncertain Tax Positions (UTPs)

Sutherland: Bringing Certainty to an Uncertain Tax Position: IRS LB&I Directive Addresses Partial Worthlessness Deductions Claimed by Insurance Companies

Alston + Bird: Dealing with Financial Auditors and Schedule UTP

Vinson & Elkins: The Uncertain World of Uncertain Tax Position Disclosures and Privilege

Taxation of Carried Interests

Kelley Drye: Obama Pushes Carried Interest to the Fore of U.S. Tax Policy Debate

Willkie Farr & Gallagher: Preparing for the Possible Enactment of Carried Interest Legislation

Kramer Levin: NYC DOF Discontinues Investment Fund Audit Position