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Regulations

Final, temporary & proposed regs explain new PEO voluntary certification program

Final, temporary & proposed regs explain new PEO voluntary certification program

IR 2016-74 T.D. 9768, “Certified Professional Employer Organizations; Final and Temporary Regulations.” Proposed Regs [REG-127561-15], “Certified Professional Employer Organizations; Notice of Proposed Rulemaking and Notice of Proposed Rulemaking by Cross-Reference to Temporary Regulations.” IRS has issued final and temporary regs implementing a new voluntary certification program for professional employer organizations (PEOs), which was authorized by […]

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Recent proposed Code Sec. 385 (debt versus equity) regs would bring sweeping changes

Recent proposed Code Sec. 385 (debt versus equity) regs would bring sweeping changes

Preamble to Prop Reg 04/05/2016; Prop Reg § 1.385-1, Prop Reg § 1.385-2, Prop Reg § 1.385-3, Prop Reg § 1.385-4 If finalized, recently issued proposed Code Sec. 385 regs would introduce sweeping changes to the treatment of related-party indebtedness, including extensive due diligence and documentation requirements (which would be applicable to cash pooling arrangements). […]

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Final regs allow wider range of foundation program-related investments

Final regs allow wider range of foundation program-related investments

T.D. 9762, 04/21/2016; Reg. § 53.4944-3 IRS has issued final regs that provide guidance to private foundations on program-related investments (PRIs) — i.e., certain types of investments made by private foundations for charitable purposes that are excepted from treatment as “jeopardizing investments” subject to excise tax under Code Sec. 4944. The final regs, which largely […]

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Proposed reliance regs on taxation, withholding, reporting of adjustments to stock rights

Proposed reliance regs on taxation, withholding, reporting of adjustments to stock rights

Preamble to Prop Reg 04/12/2016; Prop Reg § 1.305-1, Prop Reg § 1.305-3, Prop Reg § 1.305-7 , Prop Reg § 1.860G-3, Prop Reg § 1.861-3, Prop Reg § 1.1441-2, Prop Reg § 1.1441-3, Prop Reg § 1.1441-7 , Prop Reg § 1.1461-2 , Prop Reg § 1.1471-2, Prop Reg § 1.1473-1, Prop Reg § […]

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Final material advisor list penalty reg somewhat less harsh than earlier proposed reg

Final material advisor list penalty reg somewhat less harsh than earlier proposed reg

T.D. 9764, 04/27/2016; Reg. § 301.6708-1 IRS has issued a final reg on the Code Sec. 6708 penalty for material advisors’ failure to make available upon IRS’s request lists of advisees with respect to reportable transactions. The final reg makes a number of changes to the proposed reg, most of which will somewhat lessen the […]

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IRS will withdraw parts of recently-issued proposed pension plan nondiscrimination regs

IRS will withdraw parts of recently-issued proposed pension plan nondiscrimination regs

Ann. 2016-16, 2016-18 IRB IRS has announced that it will withdraw certain provisions contained in proposed regs issued this past January that would have changed nondiscrimination requirements applicable to qualified retirement plans. Background — before the proposed regs. In general, under Code Sec. 401(a)(4), a plan is a qualified plan only if the contributions or […]

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New proposed regs on when related party debt is treated as equity

New proposed regs on when related party debt is treated as equity

Preamble to Prop Reg04/05/2016; Prop Reg § 1.385-1, Prop Reg § 1.385-2, Prop Reg § 1.385-3, Prop Reg § 1.385-4 IRS has issued proposed regs under Code Sec. 385 that would: (1) authorize IRS to treat certain related-party interests in a corporation as indebtedness in part and stock in part; (2) establish documentation requirements that […]

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Final regs cover nonrecognition transfers of loss property to corporations

Final regs cover nonrecognition transfers of loss property to corporations

T.D. 9759, 03/25/2016; Reg. § 1.332-6, Reg. § 1.332-7, Reg. § 1.334-1, Reg. § 1.337-1, Reg. § 1.351-3, Reg. § 1.358-6, Reg. § 1.362-3, Reg. § 1.362-4, Reg. § 1.368-3 IRS has issued final regs on the Code Sec. 334(b)(1)(B) and Code Sec. 362(e)(1) anti-loss importation provisions that are designed to prevent erosion of the […]

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IRS issues final regs eliminating & modifying exceptions to coordination rule

IRS issues final regs eliminating & modifying exceptions to coordination rule

Reg. § 1.367(a)-3; Reg. § 1.367(a)-6; Reg. § 1.367(a)-6T; Reg. § 1.1248(f)-3 ; Reg. § 1.6038B-1 TD 9760, Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations (Mar. 18, 2016). IRS has issued final regs, generally adopting temporary regs issued in 2013, that eliminate an exception to […]

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Final Regs eliminate & modify exceptions to coordination rule for certain outbound transfers

Final Regs eliminate & modify exceptions to coordination rule for certain outbound transfers

TD 9760, Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations (Mar. 18, 2016). IRS has issued final regs, generally adopting temporary regs issued in 2013, that: (i) eliminate an exception to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations; […]

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IRS withdraws portions of older proposed regs that are replaced by new guidance

IRS withdraws portions of older proposed regs that are replaced by new guidance

Partial Withdrawal of Proposed Application of Section 367 to a Section 351 Exchange Resulting From a Transaction Described in Section 304(a)(1); Partial Withdrawal of Proposed Guidance for Determining Stock Ownership. IRS has partially withdrawn portions of two sets of proposed regs issued in 2009 and 2014. The withdrawn portion of the 2009 proposed regs no […]

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Temporary regs counter inversions and post-inversion tax avoidance transactions

Temporary regs counter inversions and post-inversion tax avoidance transactions

T.D. 9761, 04/05/2016, Reg. § 1.304-7T , Reg. § 1.367(a)-3T, Reg. § 1.367(b)-4T, Reg. § 1.956-2T, Reg. § 1.7701(l)-4T , Reg. § 1.7874-1T, Reg. § 1.7874-2T , Reg. § 1.7874-3T, Reg. § 1.7874-4T, Reg. § 1.7874-6T, Reg. § 1.7874-7T, Reg. § 1.7874-8T , Reg. § 1.7874-9T, Reg. § 1.7874-10T , Reg. § 1.7874-11T, Reg. § […]

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Temporary and proposed reliance regs on inherited property consistent basis rules

Temporary and proposed reliance regs on inherited property consistent basis rules

T.D. 9757, 03/02/2016; Reg. § 1.6035-2T; Preamble to Prop Reg 03/02/2016; Prop Reg § 1.1014-10 , Prop Reg § 1.6035-1, Prop Reg § 1.6035-2, Prop Reg § 1.6662-8 , Prop Reg § 301.6721-1, Prop Reg § 301.6721-2 IRS has issued temporary regs that confirm the recently-delayed due date for providing statements to IRS and to […]

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IRS amends transition rules in proposed reliance tax-exempt bond regs

IRS amends transition rules in proposed reliance tax-exempt bond regs

Correction to REG-129067-15, Definition of Political Subdivision. IRS has published a correction to proposed reliance regs, issued last month, that would redefine the term “political subdivision” for tax-exempt bond purposes. The regs’ applicability date was subject to a number of transition rules that IRS has now amended in light of comments received. Background. Under Code […]

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Final litigation cost award regs and revenue procedure include pro bono rules

Final litigation cost award regs and revenue procedure include pro bono rules

T.D. 9756, 02/29/2016; Reg. § 301.7430-1, Reg. § 301.7430-2, Reg. § 301.7430-3 , Reg. § 301.7430-4, Reg. § 301.7430-5, Reg. § 301.7430-6 , Reg. § 301.7430-7; Rev Proc 2016-17, 2016-11 IRB IRS has issued final regs that reflect changes made to Code Sec. 7430 (relating to awards of administrative costs and attorneys fees) by the […]

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Final & temporary regs and Rev Proc modify low-income housing credit monitoring rules

Final & temporary regs and Rev Proc modify low-income housing credit monitoring rules

T.D. 9753, 02/23/2016; Reg. § 1.42-5; Reg. § 1.42-5T; Preamble to Prop Reg 02/23/2016; Prop Reg § 1.42-5; Rev Proc 2016-15, 2016-11 IRB TD 9753, Low-Income Housing Credit Compliance-Monitoring Regulations. PR 15034912, Notice of Proposed Rulemaking, Low-Income Housing Credit Compliance-Monitoring Regulations. IRS has issued final and temporary regs, the text of which also serves as […]

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Final reg authorizes more return information disclosures to Census Bureau

Final reg authorizes more return information disclosures to Census Bureau

T.D. 9754, 02/24/2016; Reg. § 301.6103(j)(1)-1 TD 9754, Disclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce for Certain Statistical Purposes and Related Activities. IRS has issued a final reg that authorizes the disclosure of certain items of return information to the Census Bureau pursuant to Code Sec. […]

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Final regs on foreign financial asset reporting by domestic entities

Final regs on foreign financial asset reporting by domestic entities

T.D. 9752, 02/22/2016; Reg. § 1.6038D-1, Reg. § 1.6038D-2, Reg. § 1.6038D-6 IRS has issued final regs on the application of the rules that require certain domestic entities to annually report their interest in certain foreign financial assets. The final regs are effective for tax years that begin after Dec. 31, 2015. Background. Specified individuals […]

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Proposed reliance regs redefine “political subdivision” for tax-exempt bond purposes

Proposed reliance regs redefine “political subdivision” for tax-exempt bond purposes

Preamble to Prop Reg 02/22/2016, Prop Reg § 1.103-1 IRS has issued proposed regs that would provide a new definition of a political subdivision for purposes of tax-exempt bonds and would update and streamline other portions of the existing Code Sec. 103 regs. The proposed regs are generally effective 90 days after being finalized; however, […]

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Final & temporary regs amend utility allowance rules for low-income housing credit

Final & temporary regs amend utility allowance rules for low-income housing credit

T.D. 9755, 03/02/2016; Reg. § 1.42-10; Reg. § 1.42-10T; Reg. § 1.42-12; Preamble to Prop Reg03/02/2016; Prop Reg § 1.42-10 IRS has issued final and temporary regs, the text of which serves as the text of contemporaneously issued proposed regs, that amend the existing utility allowance regs concerning the low-income housing credit. Specifically, the final […]

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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