In this article, Miller &
On September 21, 2017, the Internal Revenue Service (IRS) introduced a pilot program that expands the scope of letter rulings available for distributions intended to qualify as tax-free spin-offs u
In this article, David Zimmerman, Layla Asali, A
On April 4, 2016, proposed regulations ("Proposed Regulations") under Internal Revenue Code section 3851 were issued that generally recharacterize related party debt as equity in whole o
On Thursday, November 19, 2015, the U.S.
The Bipartisan Budget Act of 2015 (the Act)1 that was signed into law on November 2, 2015, dramatically changes the rules for Internal Revenue Service (IRS) audits of partnerships and in
In this article, Patricia Sweeney, Alan Horowitz and Andrew Howlett discuss the Tax Court's decision in Altera Co
In Altera Corp. v. Commissioner, 145 T.C. No. 3 (July 27, 2015), the Tax Court put the Internal Revenue Service (IRS) and U.S.
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