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Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more
The Tax Cuts and Jobs Act of 2017 increased the federal estate and gift tax exclusion amount (sometimes called the “basic exclusion amount” or “BEA”) from $5 million to $10 million. (Those numbers are adjusted for...more
The IRS recently released proposed clawback regulations on the treatment of gifts that are complete at the time of transfer but are potentially included in the donor's gross estate at death. Such gifts will likely get the...more
The Treasury Department issued proposed regulations on Tuesday, April 26, 2022 in follow up to the anti-clawback regulations published on November 26, 2019. The 2019 anti-clawback regulations were in response to the Tax Cuts...more
If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more
On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more
Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more
On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more
The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more
On February 26, 2020, the IRS published proposed regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) regarding the elimination of deductions for entertainment and the limitation on food and...more
Two months have elapsed since Treasury and IRS issued the Final Regulations on Opportunity Zones. The effective date is March 13, 2020. During these two months, the Sullivan Ozone Practice Group has hosted gatherings for our...more
On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more
On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more
The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
Estate, Gift and GST Tax Update - What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7 – October 11, 2019. October 7, 2019: The IRS announced that taxpayers who requested...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more
What’s a clawback ? and should you be worried about it? By temporarily doubling the gift and estate tax exemption amount, the Tax Cuts and Jobs Act created an historic opportunity for affluent families to shelter wealth...more
On September 5, 2019, the Treasury Department (Treasury) and the IRS released proposed regulations (Regulations) that would impact when accrual method taxpayers report amounts in gross income. Generally, Section 451 provides...more