Back in April, the administration previewed coming changes to the Cuba embargo, suggesting that it would further restrict travel between the U.S. and Cuba.
Effective May 16, 2019, the U.S.
On January 18, 2018, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations under section 199A (the Final Regulations).1 Section 199A is
On November 20, 2018, the Internal Revenue Service's (IRS) Criminal Investigation Division (CI) issued a memorandum (the Updated Practice) providing significant guidance on voluntary disclosures (b
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
In this article, Layla Asali, Andrew Howlett, Katherine Zhang,* and David Zimmerman discuss Revenue Procedure 2017-52, which describes the Internal Revenue Service's (IRS's) pilot program that expa
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
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