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Results:1-10 of 71

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


Valuation Discounts for Transfers of Interests in Family Entities May Be Severely Curtailed - You May Want To Act Now
  • Proskauer Rose LLP
  • USA
  • August 10 2016

On August 2, 2016, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations under section 2704 (the "Proposed


Deferred Compensation for Tax-exempt Organizations: New Proposed Regulations under Code Section 457
  • Proskauer Rose LLP
  • USA
  • July 15 2016

On June 21, 2016, the Internal Revenue Service (IRS) issued anticipated proposed Treasury Regulations prescribing rules under Section 457 of the


IRS Releases Proposed Regulations To Clarify Section 409A Provisions
  • Proskauer Rose LLP
  • USA
  • July 14 2016

The Internal Revenue Service (IRS) recently issued proposed Treasury Regulations (available here) that would clarify certain provisions of the final


Lawsuits Filed Challenging the USDOL's Final Fiduciary Rules
  • Proskauer Rose LLP
  • USA
  • June 4 2016

On April 6, 2016, the U.S. Department of Labor released its Final Rule addressing when a person providing services to an employee benefit plan or


Relief for correcting certain Internal Revenue Code Section 409a failures expires this year
  • Proskauer Rose LLP
  • USA
  • November 15 2012

The Treasury Department and the IRS have provided favorable transition relief for correcting arrangements that impermissibly condition the payment of nonqualified deferred compensation on a service provider's completion of certain employment-related actions (such as the execution of a non-competition agreement, non-solicitation agreement or release of claims).


IRS and Treasury Department publish anticipated guidance on "dividend equivalent" payments derived from equity swap arrangements
  • Proskauer Rose LLP
  • USA
  • January 27 2012

On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section 871(m) and related Sections of the Internal Revenue Code of 1986, as amended (the "Code").


IRS-Treasury annual Priority Guidance Plan released
  • Proskauer Rose LLP
  • USA
  • December 15 2010

Last week, the IRS and Treasury Department released their annual Priority Guidance Plan for the 2010-2011 federal fiscal year.


Important IRS guidance on tax treatment of health coverage for children under age 27
  • Proskauer Rose LLP
  • USA
  • April 28 2010

On April 27, 2010, the Internal Revenue Service (the "IRS") issued Notice 2010-38 (the "Notice"), which provides important guidance regarding the tax treatment of employer-provided health coverage to employees' adult children.


Pamela A Onufer
  • Proskauer Rose LLP