IRC section 704(b) that severely restricted the amount of flexibility that partnerships enjoyed over However, given a tax rate of less than 100%, partners that received cash could Stephen G. Utz,Partnership Taxation in Transition: Of Form, Substance, and Economic Risk, 43 TaxHaden, Ed R...
On March 5, 2024, the IRS issued final regulations under Internal Revenue Code Section 6417 (the “Final Regulations”) with respect to energy tax credits which are directly payable to State and local governmental entities as...more Spring Cleaning for your Nonprofit: Dusting Off Your Articles,...
Section 1.163(j)-1(b)(22)(v)(E), Example 5. Implications: The exclusion of a guaranteed payment for the use of capital as interest in the Final Regulations is a taxpayer favorable modification to the definition of interest for purposes of IRC Section 163(j). Partnerships that ...
Internal Revenue Service (IRS). It mentions that the NPRM is aimed to clarify the boundaries of "social welfare organizations" under Section 501 of the Internal Revenue Code (IRC).Gorovitz, EricInternational Journal of Not-for-Profit Law
Wilkins (IRS) Re: Possible New Regulations under IRC Section 2704(b)doi:10.2139/ssrn.2655187Comments to Treasury and the IRS on possible new regulations to be promulgated under Internal Revenue Code Section 2704(b) -- enacted as part of Chapter 14 in 1Social Science Electronic Publishing...
Proposed Regulations Released on IRC Section 199A Pass-Through DeductionPeter J. UlrichTodd M. Kellert
New Proposed Regulations Issued Under IRC Section 409ARandall C. McGeorge
Tax professionals have become increasingly aware of problems associated with classification of securities as debt or equity interests, particularly in closely held corporations. This tax area is abundant with litigation striving to carve distinctions betweenBoyles, Jesse V. IIITax Executive...
It intends to provide plan sponsors with a road map for complying with the final regulations, a general overview of the new rules, and discusses the arrangements that are subject to IRC Section 409A.MongFirmKeithFirmA.FirmJournal of Pension Planning & Compliance...
New Proposed Regulations Clarify and Add Flexibility to IRC Section 409A RegulationsSchneider, Paul J.