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Treasury Official Discusses Planned Guidance on International Issues

On December 5, 2011, Treasury Deputy International Tax Counsel Danielle Rolfes discussed the points on which the Treasury hopes to issue guidance before the end of the year. Most prominent among the items mentioned are final cost-sharing regulations under Section 482. The final regulations will be based on the current temporary regulations which expire at…

IRS Issues Final Regulations on Disclosure of Reportable Transactions for Generation-Skipping Transfers

On November 28, 2011, the Treasury Department issued T.D. 9556, providing final regulations on the disclosure of reportable transactions related to generation-skipping transfers. The final regulations modify previous final regulations issued in 2007 and do not deviate from 2009 proposed regulations. Commentators expressed concern that the proposed regulations may permit a corporate fiduciary to be…

Treasury Issues Proposed Regulations Regarding Material Participation

On November 25, 2011 the Treasury Department issued proposed regulations relating to the definition of an “interest in a limited partnership as a limited partner.” Specifically, the proposed regulations address the situations wherein a member of an LLC will be treated as not owning an interest in a limited partnership as a limited partner under…

IRS Offering Employers An Opportunity to Reclassify Workers Without Penalty

On November 17, 2011, Janine Cook, Deputy Division Counsel/Associate Chief Counsel of the IRS Tax Exempt and Government Entities Division announced that IRS anticipated issuing new Frequently Asked Questions regarding the Service’s Voluntary Classification Settlement Program (VCSP). VCSP is a new program which allows employers to reclassify workers as employees for future tax years and…

The changing interpretation of the Law on includable Supply Costs for the R&D Credit as decided in the Union Carbide, TG Missouri & Trinity lawsuits

These three cases, Union Carbide Corp. v. Comm’r, TG Missouri Corp. v. Comm’r, and Trinity Indus, Inc. v. U.S., will have a substantial impact on an issue that has rarely been discussed at length in the courts: the qualification of supply costs for the R&D credit. In the Union Carbide lawsuit, the taxpayer (UCC), a…
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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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