This spring, the Office of the Chief Counsel of the Internal Revenue Service (IRS) released three Chief Counsel Advice (CCA) memoranda regarding a variety of compensatory tax issues. Spec...
On March 31, 2015, the Internal Revenue Service published final regulations under Section 162(m) of the Internal Revenue Code. The final regulations clarify two requirements for exception...
The Treasury Department and the IRS recently released Notice 2014-52 (the “Notice”), which describes regulations that the government intends to issue to target the tax benefits of cor...
The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that the government intends to issue to target the tax benefits of co...
A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corporate inversions was made publicly available yesterday. Senator S...
As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantly limit, for a two-year period, the ability of U.S. corporations ...
The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “Temporary Regulations”) incorporating and expanding upon the ru...
On January 4, 2013, the Sixth Circuit denied the U.S. government’s petition for en banc review of its September 2012 decision in United States v. Quality Stores that certain severance p...
Today the House passed H.R. 4213, “American Jobs and Closing Tax Loopholes Act of 2010.” The bill contains both new proposals and proposals that were included in the Administration’...
