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Proposed Partnership Audit Regulations Reissued in Substantially Identical Form
  • Proskauer Rose LLP
  • USA
  • June 14 2017

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG


Standing in the Shoes of a Suspended Corporation under California Law
  • Proskauer Rose LLP
  • USA
  • June 13 2017

A California Court of Appeal recently provided a reminder that under Code of Civil Procedure 368, assignment of a right to recover money


The Time is Right to Contact Recordkeepers About Hardship Substantiation
  • Proskauer Rose LLP
  • USA
  • May 23 2017

If your 401(k) plan recordkeeper has not talked to your company lately about hardship distributions, it may be time to reach out to the recordkeeper


IRS Issues Guidance on “North-South” Transactions
  • Proskauer Rose LLP
  • USA
  • May 16 2017

On May 3, the Internal Revenue Service (the IRS) issued Revenue Ruling 2017-09 (the “Ruling”), which helpfully clarifies that the separate steps of a


UPDATE: President Trump Signs “Johnson Amendment” Executive Order Limiting Treasury’s Actions Against Religious Organizations Engaged in Political Campaign Activities
  • Proskauer Rose LLP
  • USA
  • May 9 2017

On May 4, 2017, President Trump signed an Executive Order that directs the Executive Branch to limit its enforcement of the “Johnson


Wealth Management Update - May 2017
  • Proskauer Rose LLP
  • USA
  • May 9 2017

The May 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4, down 0.2 from April. The May applicable


Protecting Your Qualified Retirement Plan Now that the IRS Determination Program is (Mostly) Closed
  • Proskauer Rose LLP
  • USA
  • May 3 2017

A lot has been written over the last few months about what to do now that the IRS has closed its determination letter program for ongoing individually


Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges
  • Proskauer Rose LLP
  • USA
  • April 27 2017

Last week, in McKelvey v. Commissioner the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not


Trump Administration Announces Outline of Its Tax Proposal
  • Proskauer Rose LLP
  • USA
  • April 27 2017

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax


IRS Updates FATCA FAQs, Addresses January Temporary Regulations
  • Proskauer Rose LLP
  • USA
  • April 25 2017

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act