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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


IRS Issues Temporary Enforcement Policy In Line with DOL FAB 2017-01
  • Proskauer Rose LLP
  • USA
  • March 30 2017

On the heels of the Department of Labor’s temporary Enforcement Policy concerning the DOL Conflict of Interest Rule and related exemptions (see our


Is It the End of the Johnson Amendment as We Know It?
  • Proskauer Rose LLP
  • USA
  • March 3 2017

While speaking at the National Prayer Breakfast on February 2, 2017, President Trump reaffirmed his commitment to repeal the law that restricts


IRS Issues Final Regulations on REIT and RIC Conversion Transactions
  • Proskauer Rose LLP
  • USA
  • February 8 2017

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing


IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans
  • Proskauer Rose LLP
  • USA
  • February 7 2017

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code


Wealth Management Update - February 217
  • Proskauer Rose LLP
  • USA
  • February 2 2017

The February 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.6, up 0.2 from January. The February


Courts Split on Definition of a “Return” for Tax Discharge
  • Proskauer Rose LLP
  • USA
  • January 6 2017

On October 11, 2016, Martin Smith petitioned the Supreme Court for a writ of certiorari to review a decision by the Ninth Circuit. After Smith failed


Back from the Dead - Cures Act Resurrects Premium Reimbursement Arrangements for Small Employers
  • Proskauer Rose LLP
  • USA
  • December 19 2016

Last week, President Obama signed the 21st Century Cures Act (the “Cures Act”), which contains numerous provisions touching on a wide range of public