Legal Updates & Commentary for Tax & Estate Planning
Earlier this year, the President directed the Secretary of the Treasury to review all “significant tax regulations” issued on or after January 1, 2016, and to take steps to alleviate the burden of regulations that meet certain criteria.
Although not falling within the literal reach of this directive, but perhaps in…
The IRS continues to issue guidance in the much debated area of corporate spinoffs. A recently published ruling examined the federal income tax treatment of the two steps that comprise a so-called “north-south” transaction.” In doing so, it provides taxpayers with some welcome certainty.
A “north-south” transaction is one in which a parent corporation (…
WTH?
It is not unusual to come across an IRS letter ruling that elicits the following reaction from many of its readers: “why did they expend the time and money to request this ruling?”
On the face of such a ruling, the IRS’s response may seem pretty obvious; even if the readers could not cite…
“Tax-Free” Basics
In general, gain or loss must be recognized upon the exchange of property by a taxpayer if the new property differs materially, in kind or extent, from the old property.
The purpose of the so-called “reorganization” provisions of the Code is to except from this general rule certain specifically described corporate exchanges that…
