Summary : While TARP's requirements are technically limited to the most highly paid employees in the companies receiving TARP funds, they promise to have far-reaching implications for executive compensation best practices. This Emerging ...

A challenge encountered by tax practitioners when attempting to draft target partnership allocations is how to deal with nonrecourse liabilities. The target allocation provision may satisfy the nonrecourse deduction safe harbor if allocations under the ...

Applying target allocations is one way to allocate income, gain, loss, deduction from a partnership. Target allocations say how cash is distributed from operations and in liquidation. This allocates income and loss to partners capital accounts so these ...

It is important to properly draft target allocation provisions, by examining a variety of such provisions. Certain partnership allocations concern income, gain, loss, and deductions, called target allocations. Target allocations specify how cash is dis ...

The global economic crisis has two diametrically opposed aspects, as things stand today. The first of these has created the current focus on economic stimulus; of getting consumers to consume; of encouraging lenders to lend; and of reenergizing the ban ...

SUMMARY : The deductibility of premiums is a potential tax benefit in a corporation forming a captive insurer. The courts have limited the deductibility of premiums to those situations in which the insurance issued by the captive is act ...

SUMMARY: Embedded in the Affordable Health Choices Act of 2009 are two pieces of tax legislation that can potentially cause uncertainty for multinational enterprises.

SUMMARY : There are a number of reporting obligations that must be complied with to avoid criminal and civil penalties in connection with foreign bank accounts. This year, the IRS, Department of Justice, President Obama and Congress hav ...

Summary : A tender offer followed by a back-end merger can be structured as an integrated transaction. Where such structure is agreed to by acquiror and the target, it is easy to establish that the parties intended an integrated transac ...

On August 19, 2009, the United States, Internal Revenue Service and UBS AG resolved their year long dispute over the summons which was served upon UBS by the Internal Revenue Service on July 21, 2008. The IRS announced (IR-2009-84) on September 21, 200 ...

Summary : A businesss goodwill and going concern value or other intangibles are often its most valuable assets. The interaction of the rules concerning acquisitions using tax partnerships and the Section 197 rules for transferred intang ...

The United States Court of Appeals for the First Circuit, sitting en banc , has ruled that tax accrual work papers, prepared by a publicly-traded corporation to produce financial statements which are certified by an independent auditor pursuant ...

Rufus v. Rhoades analyzes tax implications tied to ownership of real property interests by foreign persons, including:

Rufus v. Rhoades reviews the rules which apply to U.S. citizens and residents who live abroad for one year or more, and it discusses eligibility for benefits under IRC Section 911, the amount that is excludable from gross income, the housin ...

IRC Section 1202(a)(3) was added by the American Recovery and Reinvestment Act of 2009 (“the Act”). It encourages individuals to make investments in corporations by allowing them to temporarily exclude a greater amount of the gain on the sa ...