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The Tenth Circuit has affirmed a 2017 Tax Court decision concluding ESOPs are treated as trusts when applying certain related party rules.
The new disclosure will likely be used to gauge virtual currency noncompliance and may require disclosure of the six most recent tax years.
LB&I will apply a two-step program to identify the largest and most complex taxpayers that have the highest compliance risk.
Withholding generally applies to transfers of partnership interests by foreign persons, regulations generally follow previous guidance.
Ruling concludes certain redemption payments treated as distributions should be tax-free to the extent of undistributed S corp earnings.
Cayman Islands will accept Cayman FATCA and CRS reports, originally due May 31, through July 31, 2019, without penalty.
Eleventh Circuit affirms Tax Court’s ruling that an S corporation shareholder will not get basis for amounts advanced by related entities.
The IRS ruled that provisions in the agreement triggered upon termination of an employee-shareholder’s employment would be ignored.