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Tax Alerts

Court confirms S corp cannot deduct accruals to ESOP participants

Court confirms S corp cannot deduct accruals to ESOP participants

The Tenth Circuit has affirmed a 2017 Tax Court decision concluding ESOPs are treated as trusts when applying certain related party rules.

  • Ed Decker
  • |
  • May 20, 2019
New IRS preclearance disclosure form includes cryptocurrencies

New IRS preclearance disclosure form includes cryptocurrencies

The new disclosure will likely be used to gauge virtual currency noncompliance and may require disclosure of the six most recent tax years.

  • Tamarah Francois-Peek, Jamison Sites, Aureon Herron-Hinds
  • |
  • May 20, 2019
New LB&I exam selection program announced

New LB&I exam selection program announced

LB&I will apply a two-step program to identify the largest and most complex taxpayers that have the highest compliance risk.

  • John Deininger, Alina Solodchikova
  • |
  • May 20, 2019
Proposed regulations issued for withholding on partnership transfers

Proposed regulations issued for withholding on partnership transfers

Withholding generally applies to transfers of partnership interests by foreign persons, regulations generally follow previous guidance.

  • Ben Wasmuth, Aureon Herron-Hinds
  • |
  • May 16, 2019
IRS addresses treatment of redemption payment by terminated S corp

IRS addresses treatment of redemption payment by terminated S corp

Ruling concludes certain redemption payments treated as distributions should be tax-free to the extent of undistributed S corp earnings.

  • Ed Decker
  • |
  • May 14, 2019
Cayman gives FIs until July 31, 2019 to file FATCA and CRS reports

Cayman gives FIs until July 31, 2019 to file FATCA and CRS reports

Cayman Islands will accept Cayman FATCA and CRS reports, originally due May 31, through July 31, 2019, without penalty.

  • Aureon Herron-Hinds, Tamarah Francois-Peek
  • |
  • May 09, 2019
Upper court affirms decision denying S corp shareholder losses

Upper court affirms decision denying S corp shareholder losses

Eleventh Circuit affirms Tax Court’s ruling that an S corporation shareholder will not get basis for amounts advanced by related entities.

  • Ed Decker, Kyle Brown
  • |
  • May 09, 2019
S corp's buy-sell agreement did not create second class of stock

S corp's buy-sell agreement did not create second class of stock

The IRS ruled that provisions in the agreement triggered upon termination of an employee-shareholder’s employment would be ignored.

  • Ed Decker, Richard Wehrheim
  • |
  • May 08, 2019

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