The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign
Read more →In an audit report released on October 23, 2014, the Treasury Inspector General for Tax Administration (TIGTA) has found that the IRS should revise its procedures to better ensure protection of federal tax information scheduled to be released to the health care exchanges under the Patient Protection
Read more →The federal calculator used to determine whether an employer-sponsored insurance plan provides minimum value under the Patient Protection and Affordable Care Act (PPACA) (P.L. 111-148) appears to be malfunctioning, according to benefits experts who are eagerly awaiting guidance from the Treasury Department on a possible fix. The
Read more →The IRS has provided transition relief for its change in the one-per-year limit imposed on tax-free rollovers between Individual Retirement Account (IRA) announced in March 2014. and scheduled to go into effect January 1, 2015. Under the change, the one-per-year rule applies to each individual rather than
Read more →The 2015 tax-filing season will likely be the worst in nearly 30 years, according to National Taxpayer Advocate Nina E. Olson, who spoke to tax practitioners on November 3 at the AICPA’s National Tax Conference in Washington, D.C. Olson told attendees that the filing season will be
Read more →The IRS has announced that the Department of Health and Human Services (HHS) and the Treasury Department (including the IRS) will soon issue proposed regulations providing that a group health plan does not provide minimum value if it excludes substantial coverage to employees for in-patient hospitalization services
Read more →Entrepreneurs! When starting a business, you may experience many setbacks. But don’t let those setbacks pile up to eventually become failures that beat you down enough to want to give up. Reaching success does not guarantee you will not fail along the way. It means that you
Read more →Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found
Read more →The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their
Read more →IRS Chief Counsel (CCA 201436049) has concluded that so-called limited partners of an investment management firm were not limited partners of the firm (a limited liability company (LLC) treated as a partnership) and were being paid compensation for services. Therefore, the amounts they received from the firm
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