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Results:1-10 of 141

New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs
  • Proskauer Rose LLP
  • USA
  • September 21 2018

On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation


U.S. Treasury to Review FinCEN’s Cryptocurrency Practices
  • Proskauer Rose LLP
  • USA
  • November 29 2017

In October, the U.S. Department of the Treasury (the “Treasury”) released its Annual Plan, outlining the Office of Inspector General’s audit and


Wealth Management Update - November 2017
  • Proskauer Rose LLP
  • USA
  • November 1 2017

The November 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4, up from 2.2 in October. The November


IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)
  • Proskauer Rose LLP
  • USA
  • October 18 2017

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue


Wealth Management Update - September 2017
  • Proskauer Rose LLP
  • USA
  • September 5 2017

As part of our ongoing efforts to keep wealth management professionals informed of recent developments related to our practice area, we have


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


California District Court Addresses Whistleblower’s Self-Help
  • Proskauer Rose LLP
  • USA
  • March 3 2017

In Erhart v. BofI Holding, Inc., Case No. 15-cv-02287, (S.D. Cal. Feb. 14, 2017), a bank’s internal auditor reported alleged misconduct to federal


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


Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
  • Proskauer Rose LLP
  • USA
  • January 20 2017

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of


IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385
  • Proskauer Rose LLP
  • USA
  • October 26 2016

On October 13, 2016, the Treasury Department ("Treasury") and the Internal Revenue Service (the "IRS") issued final and temporary