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Results:1-10 of 237

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching
  • Proskauer Rose LLP
  • USA
  • March 12 2019

As discussed here, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit


IRS Expands Rules for Returning Mistaken HSA Contributions
  • Proskauer Rose LLP
  • USA
  • February 26 2019

In Notice 2008-59, the IRS provided certain limited exceptions to its previously stated general position that employers may not recoup any portion of


Proposed Rental Business Safe Harbor under Section 199A
  • Proskauer Rose LLP
  • USA
  • February 7 2019

On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the


Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
  • Proskauer Rose LLP
  • USA, OECD
  • January 25 2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid”


Interim Guidance Released on Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations
  • Proskauer Rose LLP
  • USA
  • January 15 2019

The Department of the Treasury and the Internal Revenue Service recently released Notice 2019-09 (the “Notice”), which provides Interim Guidance


IRS Releases Interim Guidance on New Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations
  • Proskauer Rose LLP
  • USA
  • January 14 2019

On December 31, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2019-09 (the “Notice”)


The Proposed BEAT Regulations
  • Proskauer Rose LLP
  • USA
  • December 31 2018

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the


Inclusion of Qualified Transportation Fringe Benefits in UBTI: Guidance, Relief, and Rumors of Possible Repeal
  • Proskauer Rose LLP
  • USA
  • December 19 2018

December 10, 2018 saw significant activity with respect to Section 512(a)(7) of the Internal Revenue Code (the “Code”), which requires tax-exempt


Wealth Management Update
  • Proskauer Rose LLP
  • USA
  • December 6 2018

Important federal interest rates continue to rise. The December applicable federal rate ("AFR") for use with a sale to a defective grantor trust


Summary of the Opportunity Zone Program
  • Proskauer Rose LLP
  • USA
  • November 8 2018

The Tax Cuts and JOBS Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is