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Results: 1-10 of 437

IRS announces Section 409A compliance program for discounted stock options

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • February 12 2007

In Announcement 2007-18, the Internal Revenue Service (IRS) introduced a compliance resolution program that will permit employers to pay the additional taxes employees have incurred under section 409A of the Internal Revenue Code (the Code) as a result of exercising discounted stock options and stock appreciation rights during 2006

The cliff-hanger (chapter one) is over: highlights of the American Taxpayer Relief Act of 2012

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • January 7 2013

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the

IRS listens to taxpayers and limits taxation of patent cross licenses

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • February 20 2007

The IRS provided a Valentine’s Day present to companies with patent cross licenses by issuing Rev. Proc. 2007-23, in which the IRS announced limited taxation of such patent cross licensing arrangements

United States Supreme Court dissects dysfunctional apportionment in MeadWestVaco Corp v Illinois Department of Revenue

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • January 17 2008

The allocation or apportionment of income from a capital gain transaction has been the subject of several U.S. Supreme Court, and hundreds of lower court, decisions

IRS issues ruling and proposed guidance regarding protected cell companies

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • January 24 2008

On February 4, 2008, the Internal Revenue Service will publish Revenue Ruling 2008-8 and Notice 2008-19, addressing tax issues arising in the context of insurance provided by “protected cell companies” i.e., generally, companies that consist of an array of separate cells, each of which is economically and legally insulated from the others

IRS issues form to report employer-owned life insurance

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • February 7 2008

The Internal Revenue Service has issued Form 8925 to report certain employer-owned life insurance contracts pursuant to Code section 6039I as enacted in the Pension Protection Act of 2006

DOL issues 403(b) guidance

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • July 25 2007

In conjunction with the publication of final tax regulations under Section 403(b), the Labor Department has issued a field assistance bulletin considering the interaction of ERISA with these final regulations

IRS to publish Section 457 guidance

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • July 24 2007

The Internal Revenue Service and the Treasury have announced their intention to publish guidance under Section 457 applicable to nonqualified deferred compensation plans of state and local governments and tax-exempt entities concerning the definitions of a bona fide severance pay plan under Section 457(e)(11) and substantial risk of forfeiture under Section 457(f)(1)(B

The Multistate Tax Commission’s 40th Annual Meeting highlights the MTC’s continuing focus on apportionment

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • August 6 2007

The 40th anniversary meeting of the Multistate Tax Commission (MTC), held in Minnesota last week, highlighted a significant number of state efforts dramatically to alter state taxation, particularly state income tax apportionment

Liberalization of variable insurance product diversification requirements proposed

  • Sutherland Asbill & Brennan LLP
  • -
  • USA
  • -
  • July 31 2007

The Internal Revenue Service (“IRS”) and Treasury published in today’s Federal Register a proposal to amend the regulations under section 817(h) of the Internal Revenue Code (“Code”), which imposes “adequate diversification” requirements on insurance company “segregated asset accounts” (i.e., separate accounts and subaccounts) supporting variable life insurance and annuity contracts (“variable contracts”

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