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IRS Chief Counsel Memorandum clarifies that correction of Section 409A failures in year of vesting will not shield income inclusion under 409A
  • Proskauer Rose LLP
  • USA
  • May 13 2015

Earlier this month, the Office of Chief Counsel of the Internal Revenue Service released a Memorandum clarifying the impact of a correction of a Code


Changes to the IRS Determination Letter program
  • Proskauer Rose LLP
  • USA
  • May 13 2015

The IRS has informally stated that it is intending to make some significant changes to the Determination Letter program, and is even considering


Wealth management update
  • Proskauer Rose LLP
  • USA
  • May 8 2015

The May 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.8, which is a slight decrease from April's rate


FINRA Chairman: SEC should lead on uniform fiduciary standard
  • Proskauer Rose LLP
  • USA
  • May 8 2015

On May 1, 2015, Richard Ketchum, Chairman and CEO of the Financial Industry Regulatory Authority ("FINRA"), reaffirmed his support for a uniform


Wealth management update
  • Proskauer Rose LLP
  • USA
  • April 22 2015

The Obama Administration has recently announced its Fiscal Year 2016 Revenue Proposals in its annual "Greenbook." The Greenbook sets forth the


IRS Commissioner says IRS is “under new management;” what’s happened over the past year in the IRS affecting tax-exempt organizations?
  • Proskauer Rose LLP
  • USA
  • April 10 2015

On March 31, 2015, the Commissioner of the IRS reported in a speech to the National Press Club that the IRS is "under new management" due to major


New York State Governor and Legislature amend and extend Brownfield Cleanup Program
  • Proskauer Rose LLP
  • USA
  • April 8 2015

Governor Andrew Cuomo and the New York State Legislature have reached an agreement to amend and extend the State's Brownfield Cleanup Program (BCP


IRS relaxes correction requirements for elective deferral (but not after-tax contribution) failures under EPCRS
  • Proskauer Rose LLP
  • USA
  • April 6 2015

Less than a week after issuing significant modifications to the Employee Plans Compliance Resolution System (EPCRS) (as described in our March 31


Proposed Treasury regulations aim to curb elective treatment of M&A transaction costs
  • Proskauer Rose LLP
  • USA
  • April 1 2015

Some taxpayers have taken the position that an acquiring corporation and a target corporation, when the target corporation is joining the acquiring


IRS modifies EPCRS guidelines, requests comments on overpayment correction
  • Proskauer Rose LLP
  • USA
  • March 31 2015

On March 27, 2015, the Internal Revenue Service (IRS) released Revenue Procedure 2015-27, which modifies, effective July 1, 2015, prior guidelines