Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Section 382

Final regs exempt certain Treasury sales of instruments from Code Sec. 382 segregation rules

Final regs exempt certain Treasury sales of instruments from Code Sec. 382 segregation rules

T.D. 9721, 06/04/2015; Reg. § 1.382-3 IRS has issued final regs that modify the effective date of previously issued regs; the effect of this modification is to exempt Treasury’s sales of instruments issued under certain Emergency Economic Stabilization Act of 2008 (EESA) programs to public shareholders, from the Code Sec. 382 segregation rules. IRS had […]

Read the full article →

IRS rejects corp’s attempt to avoid Section 382 limitation on recognized built-in loss in Chief Counsel Advice 2013-09013

IRS rejects corp’s attempt to avoid Section 382 limitation on recognized built-in loss in Chief Counsel Advice 2013-09013

In Chief Counsel Advice (CCA) 2013-09013, IRS has clarified how a loss corporation’s recognized built-in loss (RBIL) is treated under Code Sec. 382 following an ownership change. The CCA agreed with the revenue agent’s determination that the corporation couldn’t simply exclude the RBIL from its annual tax computations under Code Sec. 63(a) and Code Sec. […]

Read the full article →
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.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney