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Safe Harbor

Temp regs issued on partnership’s allocation of creditable foreign tax expenditures

Temp regs issued on partnership’s allocation of creditable foreign tax expenditures

T.D. 9748, 02/03/2016, Reg. § 1.704-1T; Preamble to Prop Reg02/03/2016, Prop Reg § 1.704-1 IRS has issued temporary regs on the operation of the safe harbor rule under Reg. § 1.704-1(b)(4)(viii), which is used in determining whether allocations of partnership creditable foreign tax expenditures to partners are deemed to be in accordance with the partners’ […]

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New guidance on permissible mid-year changes involving safe harbor plans

New guidance on permissible mid-year changes involving safe harbor plans

Notice 2016-16, 2016-7 IRB In a Notice, IRS has provided guidance on mid-year changes to a safe harbor plan under Code Sec. 401(k) and Code Sec. 401(m). A mid-year change either to a safe harbor plan or to a plan’s safe harbor notice won’t violate the safe harbor rules merely because it is a mid-year […]

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IRS extends safe harbor for governmental homeowner assistance payments through 2017

IRS extends safe harbor for governmental homeowner assistance payments through 2017

Notice 2015-77, 2015-47 IRB In a Notice, IRS has extended through 2017 earlier guidance on the tax consequences of programs that involve payments made to or on behalf of financially distressed homeowners; the guidance includes a safe harbor method for computing a homeowner’s deduction for payments made on a home mortgage. The Notice also extends […]

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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