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IRS issues Practice Unit on treatment of M&A transaction costs

IRS issues Practice Unit on treatment of M&A transaction costs

IRS issues Practice Unit addressing application of costs incurred in an M&A transaction reinforcing benefit of a transaction cost analysis.

  • Nick Gruidl
  • |
  • July 20, 2018
Importance of corporate structure for employee stock ownership plans

Importance of corporate structure for employee stock ownership plans

An IRS private letter ruling illustrates how employee stock ownership plans are governed by the corporate sponsor’s structure.

  • Anne Bushman, Keandra Greene
  • |
  • July 17, 2018
Economic substance doctrine knocks out currency option tax shelters

Economic substance doctrine knocks out currency option tax shelters

Although claimed losses were disallowed, otherwise applicable penalties were dismissed for lack of requisite approvals.

  • Ramon Camacho, Ben Wasmuth
  • |
  • July 16, 2018
IRS issues final anti-inversion regulations

IRS issues final anti-inversion regulations

Final anti-inversion regulations largely follow the 2016 proposed regulations with some limited changes and clarifications.

  • Ramon Camacho, Jamison Sites
  • |
  • July 16, 2018
S election valid despite presence of disproportionate distributions

S election valid despite presence of disproportionate distributions

Tax court rules that disproportionate distributions are insufficient to create 2nd class of stock. Decision echoes message coming from IRS.

  • Ed Decker, Kyle Brown
  • |
  • July 09, 2018
IRS LB&I division announces latest group of compliance campaigns

IRS LB&I division announces latest group of compliance campaigns

IRS LB&I has issued a fifth round of examination campaigns focused on the issues that present the most compliance risk.

  • Ramon Camacho, John Deininger, Alina Solodchikova
  • |
  • July 05, 2018
IRS releases several new international compliance campaign items

IRS releases several new international compliance campaign items

The LB&I division of the IRS has identified several international tax issues to be the focus of their new issue specific audit strategy.

  • Ramon Camacho, Kyle Brown, Jamison Sites
  • |
  • July 05, 2018
New FAQs for QIs and insurance Co.’s; Cayman FATCA portal remains open

New FAQs for QIs and insurance Co.’s; Cayman FATCA portal remains open

The IRS has published a new FATCA FAQ on good faith standard for QIs that comes amidst other information reporting updates.

  • Aureon Herron-Hinds, Kyle Brown
  • |
  • July 05, 2018

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