IRS issues Practice Unit addressing application of costs incurred in an M&A transaction reinforcing benefit of a transaction cost analysis.
An IRS private letter ruling illustrates how employee stock ownership plans are governed by the corporate sponsor’s structure.
Although claimed losses were disallowed, otherwise applicable penalties were dismissed for lack of requisite approvals.
Final anti-inversion regulations largely follow the 2016 proposed regulations with some limited changes and clarifications.
Tax court rules that disproportionate distributions are insufficient to create 2nd class of stock. Decision echoes message coming from IRS.
IRS LB&I has issued a fifth round of examination campaigns focused on the issues that present the most compliance risk.
The LB&I division of the IRS has identified several international tax issues to be the focus of their new issue specific audit strategy.
The IRS has published a new FATCA FAQ on good faith standard for QIs that comes amidst other information reporting updates.