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Foster Garvey PC

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

Foster Garvey PC on

I have feverishly been reporting about provisions of the One Big Beautiful Bill Act and have left my multi-part series on Subchapter S adrift at sea. Accordingly, I want to sneak in one more article in this Subchapter S...more

McDermott Will & Schulte

Receiving Debt-Financed Distributions From a QOF: IRS Allows Significant Flexibility (And Some Traps)

McDermott Will & Schulte on

Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more

Farrell Fritz, P.C.

Internal Revenue Service Warns of “Mills” Taking Advantage of Taxpayers With Offer in Compromise (“OIC”) Program

Farrell Fritz, P.C. on

In a recent news release (available here), the Internal Revenue Service (“IRS”) warned taxpayers about promoters claiming their services are needed to resolve unpaid taxes owed to the IRS....more

Best Best & Krieger LLP

Best in Law: Take Some Time with Your Minute Book

Best Best & Krieger LLP on

BB&K Business Attorney Brian Reider Discusses the Importance of Minute Books in the Southern California Newspaper Group - Looking back at the year, one recurring theme emerges with corporate clients and their...more

Herbert Smith Freehills Kramer

Debt-Equity Dashed Expectations: Treasury and the Service Retain Onerous Section 385 Regulations

Herbert Smith Freehills Kramer on

On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

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