Following our September 18 article, “Retirement Plan and Leave Donation Programs During States of Emergencies,” the Internal Revenue Service (IRS) and Congress acted to provide additional relief and assistance opportunities to those affected by Hurricanes Harvey, Irma, and Maria. In an effort to increase donations to assist those in need, the IRS issued guidance to allow employers to set up programs that enable employees to elect to have unused leave converted to cash ... Keep Reading »
Comprehensive Tax Reform in the News: The Republican Framework Released
On September 27, Republican leadership from the House, Senate, and the Trump administration released the “Unified Framework for Fixing Our Broken Tax Code” (the “Framework”). The Framework outlines, in largely broad, general terms, the Republican goals and vision for comprehensive tax reform. The reform’s stated goals include increasing simplicity, providing tax relief for businesses and middle-class families, and ending incentives to ship jobs, capital, and tax revenue ... Keep Reading »
Retirement Plan and Leave Donation Programs During States of Emergencies
Employers can offer retirement plans and leave donation programs with features that allow access to retirement funds or paid time off to employees in need. These features can be added using standard plan operational procedures. While we can be grateful when the IRS offers “relief” from certain requirements under certain circumstances, plan sponsors must realize that, while this relief permits employers to roll out features more quickly, it may come with a potential cost ... Keep Reading »
Statute of Limitations and International Reporting Obligations – Be Sure to Close the Door!
When it comes to federal tax matters, an important aspect of risk management includes making sure that the statute of limitations on tax assessments will expire. This is particularly important for tax years where there is a potentially contentious issue or debatable reporting position taken on the treatment of a material item. However, increasing reporting burdens imposed on international activities coupled with exceptions to the statute of limitations heighten the ... Keep Reading »
Foreign Partner’s Gain on Disposition of U.S. Partnership Interest Is Not Taxable
After great anticipation, the Tax Court has held that gain realized by a foreign corporation upon the redemption of its interest held in a U.S. partnership is non-U.S. source capital gain that was not effectively connected with a U.S. trade or business. As such, U.S. income tax could not be imposed on the gain. Although the wheels of justice often turn slowly, the Tax Court ultimately got taxpayers to the right answer in Grecian Magnesite Mining, Industrial & ... Keep Reading »