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IRS Provides Guidance on Economic Substance Doctrine

On October 9, 2014, the IRS issued Notice 2014-58, which provides much needed guidance on the economic substance penalty under IRC §7701(o). The Notice speaks to 1) the definition of “transaction”, and 2) the application of the term “similar rule of law” for accuracy related penalties under IRC §6662(b)(6). It represents the IRS’ latest effort…

Treasury Issues Regulations Aimed at Corporate Inversions

On September 22, 2014, the Department of Treasury took action against corporate inversions in Notice 2014-52. Generally speaking, an inversion occurs when a U.S. company changes its legal place of residence by restructuring and replacing the U.S. parent with a foreign parent. To accomplish an inversion, a U.S. company merges with a foreign company and…

Treasury Issues Final Regulations Relating to Deductibility of Local Lodging Expenses

Treasury recently released TD 9696, which contains final regulations relating to the deductibility of local lodging expenses. The final regulations are issued under Treas. Reg. 1.162-32. The regulations define local lodging expenses as expenses not deductible under IRC § 262(a), which disallows deductions for personal, living and family expenses. The regulations allow for the deduction…

Recent Ninth Circuit Decisions Re-Emphasize Landscape of Heightened Workforce Classification Scrutiny

On August 27, 2014, the Ninth Circuit issued two key decisions that significantly impact the ongoing landscape of worfkforce classification in holding that FedEx drivers in Oregon and California are employees, not independent contractors.  Slayman et al. v. FedEx Ground Package Sys., Inc. (Oregon); Alexander et al. v. FedEx Ground Package Sys., Inc. (California).  …

FATCA Commences—What Next for Offshore Compliance?

The Foreign Account Tax Compliance Act (“FATCA”) requires foreign financial institutions (“FFI”) that receive payments of U.S. source income to report the identity of U.S. account holders or face a 30 percent withholding tax. Under FATCA, FFIs must establish procedures for identifying and documenting whether newly opened accounts are held by U.S. individuals or entities.…
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aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2022 alliantNational. - All Rights Reserved.

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