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International and Domestic Business Taxation by Jerald David August

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The Repeal and Replacement of the TEFRA Partnership Audit Rules

FedTaxLaw Posted on December 15, 2017 by adminMarch 13, 2019

From: ALI-The Practical Tax Lawyer (Winter 2017) The Bipartisan Budget Act of 2015 made fundamental changes to how the IRS will conduct audits of partnerships. This article by Jerald David August discusses the partnership audit rules prior to and as a result of TEFRA, drafting for three regimes involving IRS audits of partnerships, the partnership “pushout” election, election out of … read more –>

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Chairman Brady issues official “Chairman’s Mark” of the Tax Cuts and Jobs Act; House Ways and Means Committee passed the historic tax bill; Senate GOP tax plan released

FedTaxLaw Posted on November 30, 2017 by adminMarch 13, 2019

House GOP Bill, H.R. 1 and Chairman’s mark amendments of November 9, 2017 On November 2, 2017, the Republican GOP released a comprehensive tax reform plan which introduced a set of individual and corporate tax reforms that have received much attention and criticism from both sides of the aisle. Summaries of the proposed legislation were described in this forum in … read more –>

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Government fires back its defense to large tax refund suit recently filed by Perrigo Co. (USA), alleging elaborate assignment of pharma licenses from U.S. subsidiary to Israeli controlled foreign corporation and related transactions were shams.

FedTaxLaw Posted on October 24, 2017 by adminMarch 13, 2019

Perrigo Company and Subsidiaries (“Perrigo”) on August 15, 2017, filed a tax refund suit against the United States in the United States District Court for the Western District of Michigan, Southern Division, No. 1:17-cv-00737. [1] Perrigo alleged it overpaid Federal income taxes, penalties and interest, for its 52-53 week tax years ending in the last week in June for the … read more –>

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US Treasury Department issues second report on identifying and reducing tax regulatory burdens; repeal of section 2704 regulations and revisions pending to the regulations issued on partnership debt

FedTaxLaw Posted on October 10, 2017 by adminMarch 14, 2019

As recently set forth in a post to K&F, LLP Business and International Tax Developments, in Executive Order 13789, President Trump directed the Treasury Department to undertake a detailed review of certain tax regulations projects that were either in proposed or final form on or after January 1, 2016 that imposed financial burdens on U.S. taxpayers, overly complicate the Federal … read more –>

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Action expected shortly by US Treasury on outbound transfers as well as other important issues, including the Branch Currency Rules

FedTaxLaw Posted on September 21, 2017 by adminMarch 14, 2019

Shortly after President Trump took the oath of office as President, on April 21, 2017, President Trump issued Executive Order 13789, a directive intended to reduce tax regulatory burdens on the IRS and Treasury.[1] The order instructed the Secretary of the Treasury to review all “significant tax regulations” issued on or after January 1, 2016 by the predecessor administration, and … read more –>

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Jerald David August,
Fox Rothschild
JAugust@foxrothschild.com

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Topics

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  • Aircraft Ownership (1)
  • ALI-CLE (2)
  • AMT (1)
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  • Deductions (1)
  • Depreciation (1)
  • Interstate Commerce (1)
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  • TCJA (4)
  • Uncategorized (6)
© 2019 Jerald David August
 
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