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Results: 1-10 of 613

Rev. Proc. 2007-65 provides no safe harbor for section 48 energy credit deals. (nor is it entirely irrelevant.)
  • Bryan Cave LLP
  • USA
  • June 30 2015

The IRS recently released a Chief Counsel Advice Memorandum (CCA 201524024) that confirms that Rev. Proc. 2007-65, which establishes a safe harbor


Advisory Committee on Tax Exempt and Government Entities (ACT) releases public report
  • Bryan Cave LLP
  • USA
  • June 26 2015

The 14th report of recommendations of the Advisory Committee on Tax Exempt and Government Entities (ACT) addresses five issues: Employee Plans:


Review of income tax deduction rules for charitable gifts
  • Bryan Cave LLP
  • USA
  • June 10 2015

According to area newspaper the St. Louis Post Dispatch, one of St. Louis’ wealthiest families, that of Enterprise Holdings founder Jack Taylor


Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?
  • Bryan Cave LLP
  • Germany, USA
  • April 29 2013

Whenever a U.S. Limited Liability Company ("US-LLC") is involved in cross-border shareholding structures concerning the United States


Federal tax consequences of trust modificationreformation: score one for the taxpayer
  • Bryan Cave LLP
  • USA
  • June 13 2013

When is a modification or reformation of an irrevocable trust given effect for Federal tax purposes? In each of two recent private letter rulings


Proposed Sec. 337(d)-7 regulations address certain transfers of property from C corporations to RICsREITs
  • Bryan Cave LLP
  • USA
  • August 9 2012

The IRS recently issued proposed regulations (the “Proposed Regulations”) that provide certain modifications to existing regulations issued under Section 337(d) of the Internal Revenue Code of 1986, as amended, relating to transfers of property from a C corporation to a regulated investment company ("RIC”) or a real estate investment trust (“REIT”


Avoiding an accuracy-related penalty for reasonable cause based on reliance on a tax professional
  • Bryan Cave LLP
  • USA
  • April 29 2013

Taxpayers seeking abatement from the accuracy-related penalty imposed under section 6662(a) of the Code often argue reasonable cause based upon


Trustees and personal representatives left holding the liability bag
  • Bryan Cave LLP
  • USA
  • October 22 2012

When is a transferee of a decedent’s assets not a transferee subject to liability under 6324(a)(2) of the Code?


Documentation hardship for hardships (and participant loans, too)
  • Bryan Cave LLP
  • USA
  • May 22 2015

What is the IRS thinking about when it announces that plan sponsors, even those using a qualified TPArecordkeeper, should maintain the records for


Mission: possiblesaving estate taxes on life insurance
  • Bryan Cave LLP
  • USA
  • June 4 2015

The trailers for the newest installment in the Mission: Impossible franchise, Mission: Impossible Rogue Nation, are being released and, as always