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Intercompany financing

IRS sets out tax treatment of a series of intercompany transfers of a wholly-owned LLC

IRS sets out tax treatment of a series of intercompany transfers of a wholly-owned LLC

Rev Rul 2015-10, 2015-21 IRB   In a Revenue Ruling, IRS has set out the tax treatment of a series of transfers of a wholly-owned limited liability company (LLC) taxable as a corporation from a parent corporation to its subsidiary and then successively to two lower-level subsidiaries, followed by the LLC electing to be treated […]

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IRS takes on Tyco in U.S. Tax Court debt-vs-equity dispute

IRS takes on Tyco in U.S. Tax Court debt-vs-equity dispute

As reported in Reuters, a U.S. Tax Court fight between Tyco International Ltd and the Internal Revenue Service reflects a growing assertiveness by the agency over deductibility of interest in certain intercompany financing deals, tax lawyers said on Wednesday. Tyco is challenging a $1 billion tax bill assessed by the IRS based on its view […]

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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