IRS Finalizes Section 385 Earnings Stripping RegulationsPeter J. Ulrich
As in PLR 202114002, Chief Counsel opined on whether the company was engaged in “brokerage services” as described in IRC section 1202(e)(3). However, unlike PLR 202114002, Chief Counsel did not simply refer to the dictionary definition of “brokerage services.” Rather, Chief Counsel reviewed...
New Spinoff Standards Proposed in IRS Regulations On Device and Active Trade or Business Under Section 355Lisa M. Zarlenga
To comply with IRS regulations: Verify tax identification numbers (TINs) of all payees to prevent mismatches with IRS records. Request updated W-9 forms when changes occur in payee status or business structure. Maintain accurate records to avoid compliance issues and ensure proper tax reporting. ...
What Regulations and Controls are Imposed by IRS 1075? To be considered compliant with IRS 1075, organizations interacting with FTI must follow all regulations set by the publication and be able to demonstrate to the IRS that they can protect the confidentiality of taxpayer information. Organizations...
the IRS regulations establish a good faith rule for determining the fair market value of stock on the date of grant of an option.26 As discussed above, the IRS has not formally adopted or applied the ISO standards, including the relatively deferential good faith rule, for IRC Section 162(m...
The Treasury Department and IRS released proposed regulations regarding the production tax credit for hydrogen under Section 45V of the Internal Revenue Code.
This section presents a summary of the article IRS Proposes a Major Revision of the Regulations Governing Section 403(b) Plans, by Stanley D. Baum, which appeared in the April 2005 issue of Journal of Taxation. On November 16, 2004, the U.S. Internal Revenue Service released proposed regul...
IRS Proposes to Update the Section 162(m) RegulationsSchneider, Paul J.Journal of Financial Service Professionals
IRS Issues Proposed Section 892 RegulationsDavid A. Sausen