Regulations to be Proposed Will Require Employer-Sponsored Group Health Plans to Include In-Patient Hospitalization Services

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

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Action Needed to Ensure Tax Compliace with FIRPTA

According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.

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US Treasury Official Discusses BEPS and Other International Tax Developments

Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

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

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Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

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

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Chief Counsel on What Makes Amounts Paid To “Limited Partners” of an LLC Subject To Self-Employment Taxes

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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