News & Analysis as of

Distribution Rules Tax Planning Internal Revenue Code (IRC)

Hogan Lovells

IRS reduces barriers to redomiciliations

Hogan Lovells on

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part IX – Taking the...

Foster Garvey PC on

Unlike the rules contained in Subchapter K surrounding partnership distributions, which tend to be somewhat complex, the distribution rules contained in Subchapter S are fairly straightforward. Nevertheless, from time to...more

Cadwalader, Wickersham & Taft LLP

IRS Releases Proposed Donor-Advised Fund Regulations

The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and...more

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

Perkins Coie on

Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more

Gray Reed

A Horse, a Horse, My Kingdom for a Horse! Lack of Proper Documentation Dooms IRS Disputes

Gray Reed on

In real life (and especially, it seems, in tax law) it is more like to be the lack of a timely piece of paper that causes the taxpayer to lose. In the course of administering a trust, it sometimes happens that mistakes...more

Seyfarth Shaw LLP

IRS Provides Additional Clarity on Key SECURE Act Provisions

Seyfarth Shaw LLP on

On December 20th, before the outbreak of COVID-19 and the resulting pandemic, President Trump signed into law the Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more

Littler

Puerto Rico Treasury Department Issues Post-Earthquake Rules for Qualified Retirement Plan and IRA Distributions and Loans

Littler on

On February 20, 2020, the Puerto Rico Treasury Department (PR Treasury) issued Internal Revenue Circular Letter Number 20-09 (CC RI 20-09) to provide special rules and procedures applicable to distributions from qualified...more

Carlton Fields

Using Nonqualified Plans to Reduce 401(k)/403(b) Costs

Carlton Fields on

This article focuses on 401(k) and 403(b) plans that are in one of the following situations: 1. The plan failed ADP or ACP testing and must distribute excess amounts to its higher-ranking employees or make additional...more

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