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Dividend

Effective date revised for recently issued dividend equivalent regs

Effective date revised for recently issued dividend equivalent regs

Correcting amendment to TD 9734 (Dec. 4, 2015) IRS has issued a correction to T.D. 9734 which changes the effective date of certain regs pertaining to the treatment of dividend equivalents under Code Sec. 871(m). The regs affected by the correction pertain to specified notional principal contracts (NPCs) and equity-linked instruments (ELIs). Background. In general, nonresident […]

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IRS revises effective date for recently issued dividend equivalent regs

IRS revises effective date for recently issued dividend equivalent regs

Correcting amendment to TD 9734 (Dec. 4, 2015). IRS has issued a correction to T.D. 9734 which changes the effective date of certain regs pertaining to the treatment of dividend equivalents under Code Sec. 871(m). The regs affected by the correction pertain to specified notional principal contracts (NPCs) and equity-linked instruments (ELIs). Background. In general, nonresident […]

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Final, etc. Regs on Payments Determined by Reference to U.S. Source Dividends

Final, etc. Regs on Payments Determined by Reference to U.S. Source Dividends

T.D. 9734, 09/17/2015; Reg. § 1.871-14, Reg. § 1.871-15, Reg. § 1.871-15T , Reg. § 1.1441-1, Reg. § 1.1441-1T, Reg. § 1.1441-2 , Reg. § 1.1441-3, Reg. § 1.1461-1, Reg. § 1.1441-7 , Reg. § 1.1473-1; Preamble to Prop Reg 09/17/2015; Prop Reg § 1.871-15 , Prop Reg § 1.1441-1 IRS has issued final regs, […]

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Managers of oil & gas properties were partners and sale of interest resulted in capital gains

Managers of oil & gas properties were partners and sale of interest resulted in capital gains

U.S. v. Stewart, et al., (DC TX 8/20/2015) 116 AFTR 2d ¶ 2015-5159 In a suit by IRS to recover tax refund claims that had been paid, a district court found that the individuals were partners in a partnership and their income was a return from an investment, rather than a commission. The court determined […]

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Proposed regs would modify determination of transactions subject to dividend equivalent rule

Proposed regs would modify determination of transactions subject to dividend equivalent rule

IRS has issued proposed regs that, according to a contemporaneously issued Treasury fact sheet, are intended to “close a tax loophole that enables non-U.S. investors to avoid paying taxes on dividends paid by U.S. companies.” Significantly, the new proposed regs would provide a “delta-based” standard to be used in determining whether a transaction is subject […]

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IRS explains on interplay of pre-2010 5-year NOL carryback and 2004 CFC repatriation holiday

IRS explains on interplay of pre-2010 5-year NOL carryback and 2004 CFC repatriation holiday

In Legal Advice Issued by Associate Chief Counsel 2013-004, the IRS has provided guidance on the interplay between a limitation on net operating loss (NOL) carrybacks to the fifth previous year under a rule that applied to certain pre-2010 years and a limitation on the amount of the dividends received deduction under the 2004 earnings […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney