Ideas & Insights

The Complex Media Tax Court case and its applicability to section 351 transactions and the step-transaction doctrine.

What are the proposed tax changes affecting individual taxpayers and what should you consider today to limit your exposure to these changes?

The IRS has issued final regulations under section 301 which become effective Sept. 22, 2021, to reflect current law.

The Puerto Rico Treasury issued guidance establishing new rules that would require a transfer pricing study to deduct cross-border expenses.

The Ways and Means Committee proposed legislation targeting digital assets to increase tax revenue via wash and constructive sales rules.

IRS waives penalty for using dyed diesel fuel on highways in several Louisiana parishes through Sept. 30, 2021.

The IRS released a summary of findings on its Appeals LB&I pilot program, and has ended mandatory participation of Exam in conferences.

The 2021-2022 Priority Guidance Plan contains anticipated guidance projects that would affect exempt organizations.

Taxpayer Advocate Service is wrestling with a backlog of cases trying to navigate the changing environment of the pandemic.

House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.

IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in Pennsylvania.

Senator Wyden’s recent ‘discussion draft’ legislation, if enacted, would drastically alter many of the tax rules that apply to partnerships.

IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in Mississippi.

IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida in New York and New Jersey.

Recent legislation extends the due date for the application from Sept. 15 to Dec. 1, allowing taxpayers more time to prepare.

The IRS will not issue PLRs on transactions involving a PF’s interest in an LLC that owns a disqualified person’s promissory note.

The IRS revises Form 6765 so in 2021 taxpayers cannot use the same wages to calculate both the R&D credit and the employee retention credit.

Senate Finance Chairman Wyden unveils draft international tax reform bill that would overhaul GILTI, FDII and BEAT rules.

Companies abandoning plans for IPO or SPAC transactions should consider the deductibility of transaction costs and termination fees.

IRS postpones certain filing, payment and other deadlines for taxpayers affected by Hurricane Ida. IRS provides additional relief.