Internal Revenue Service (IRS) on complying with section 82 of the Internal Revenue Code (IRC). The guidance offers ideas for taxpayers on dealing with the fluctuations-of-value rules found in the section. It suggests two methodologies f...
IRS Issues Guidance That Treasury's Purchase of Stocks Will Not Result in Ownership Change Under Section 382 The article reports on a notice issued by the U.S. Internal Revenue Service (IRS) which outlined guidance stating that any purchase of equity of qualifying financial institutions by the ...
(ii)the waiver of such pay under section 5305 of title 38 of such Code, as a result of an award of compensation under title 38 of such Code pursuant to a determination by the Secretary of Veterans Affairs, the 3-year period of limitation prescribed in subsection (a) shall be extended,...
IRS Takes Adverse Position in Ruling on Code Section 162(m)C. Baird Brown
Title 26 — Internal Revenue Code ("IRC") Sub Title A — Income Taxes Chapter 1 — Normal Taxes and Surtaxes Subchapter O — Gain or Loss on Disposition of Property Part III — Common Non-Taxable Exchanges Section 1031 — Table of Contents ...
The IRS and Treasury Department have requested comments be submitted on additional issues under Section 162(m) that future guidance, including regulations, should address. Specifically, comments are requested on (1) the application of the definition of “publicly held company” to foreign private issu...
The article focuses on Section 382 of the U.S. Code which restricts the extent to which a loss corporation can cancel out taxable income earned in post-ownership-change years against net operating losses (NOLs). Some of the notices issued by the U.S. Internal Revenue Service (IRS) ...
The article discusses the provision of Code Section 382 which limits the use of net operating losses after an ownership change. It is reported that Notice ... Wood,Robert,W. - 《M & A Tax Report》 被引量: 0发表: 2008年 The IRS and independent contractors The article focuses on the ser...
Joseph E. Ronan, JrLauren E. Ridley
Focus on IRS GuidanceCode Section 409A UpdateSusan Bernstein