Tax Alert

Publication
Section 355 Guidance Imposes New Minimum Thresholds for Business Assets and Provides Safe Harbors for Control/Unwind Transactions
Tax Alert
Publication
The New Debt-Equity Proposed Regulations "Invert" Existing Law for Related Party Debt
Tax Alert
Publication
Major Changes to Partnership Audit Liability
Tax Alert
Publication
Treasury Issues Final Regulations on F Reorganizations; Overlap Issues Clarified
Tax Alert
Publication
Tax Court in Altera Invalidates the Cost Sharing Regulations Provision Governing Stock-Based Compensation: The Treasury Failed to Engage in "Reasoned Decisionmaking" as Required by the APA
Tax Alert
Publication
Proposed Regulations Issued on PFIC Active Insurance Exception
Tax Alert
Publication
New Contours to the Internal Revenue Service's Application of the Economic Substance Doctrine
Tax Alert
Publication
Proposed Regulations on Partnership Hot Asset Distributions
Tax Alert
Publication
Tax Court Sanctions Computer-Aided Method for Electronic Document Production
Tax Alert
Publication
IRS Guidance Clarifies When Company Employees are Subject to Circular 230, Requiring a Power of Attorney in LB&I Examinations
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