Tax & Benefits Blog

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Dec 31, 2019

LLCs As Private Equity Fund Acquisition Vehicles for Portfolio Companies With Multiemployer Pension

On November 22, 2019, the First Circuit Court of Appeals decided Sun Capital Partners III, LP v. New England Teamsters & Trucking...

Dec 12, 2019

Incentives for Emerging Growth Companies to Revoke S Election

The Firm's article, "Incentives for Emerging Growth Companies to Revoke S Election", is forthcoming in next week's issue of Bloomberg Tax...

Nov 19, 2019

Journal of Corporate Taxation Article,

"Reporting Transfers of Partnership Interests Subject to Section 1446(f)" The Firm's article, "Reporting Transfers of Partnership...

Oct 29, 2019

H.R. 2513, Corporate Transparency Act of 2019

Introduction. On October 22, 2019, the United States House of Representatives passed H.R. 2513, titled, Corporate Transparency Act of...

Oct 17, 2019

Key Remedial Amendment Due Dates for Individually Designed 403(b) Plans Under Rev. Proc. 2019-39

Introduction. In Revenue Procedure 2019-39, effective September 30, 2019, Treasury and the IRS designated recurring remedial amendment...

Oct 3, 2019

Coordination With FIRPTA on Sale of Partnership Interests Under Proposed Section 1446(f) Regulations

Treasury and the IRS published proposed regulations, 84 Fed. Reg. 21,198 (May 13, 2019) (the “Proposed Regulations”) for withholding of...

Feb 28, 2019

Private Letter Ruling 201904008 Cautions on Nonprofit Compensation for Religious Duties

In Private Letter Ruling 201904008 (Oct. 29, 2018), published on January 25, 2019 (the “Ruling”), the Internal Revenue Service (“IRS”)...

Jun 30, 2017

IRS Finds Section 409A Failures Based on Literal Construction of Treasury Regulations and Use of Inf

Introduction: IRS Chief Counsel Advice 201725027 (Mar. 6, 2017). On March 6, 2017, the IRS issued Chief Counsel Advice 201725027...

Apr 4, 2017

IRS Form 5472 Requirements for Disregarded LLCs Wholly Owned by Foreign Exempts

Background: Foreign, Domesticated SMLLCs. Foreign charitable organizations and pension funds (hereafter, “exempts” due to their...

Feb 28, 2017

Correcting Nonqualified Deferred Compensation Plans Under Recently Proposed Regulations

Proposed Section 409A Regulations. Marina's article, "Correcting Document Failures of Plans With Nonvested Deferred Compensation Under...

Apr 7, 2015

Recent IRS Rulings Remind Charities to Avoid Grants to Pre-Selected Individuals

Recent IRS Rulings Finding Prohibited Private Benefit to Pre-Selected Individuals. The IRS issued recently several private letter...

Nov 25, 2014

Recent IRS Ruling Illuminates Procedures for Grants to Foreign Charities

On September 19, 2014, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 201438032 (I.R.S. Priv. Ltr. Rul....

May 15, 2014

May Employers Use an Involuntary Separation From Service Without Cause as an SRF?

Background. Internal Revenue Code section (“Section") 83 provides rules for timing of inclusion in income of compensation consisting of...

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