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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 IRS has partially withdrawn portions of two sets of proposed regs issued in 2009 and 2014. The withdrawn portion of the 2009 proposed regs no […]

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IRS corrects Notice announcing changes to withholding and FATCA regs

IRS corrects Notice announcing changes to withholding and FATCA regs

Notice 2016 – 08, Timing of Submitting Preexisting Accounts and Periodic Certifications; Reporting of Accounts of Nonparticipating FFIs; Reliance on Electronically Furnished Forms W – 8 and W – 9. To reduce a number of compliance burdens, IRS announced in Notice 2016-8 that it intended to amend several regs with respect to chapters 3 (withholding […]

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IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

Notice 2016-8, 2016-6 IRB In a Notice, IRS has announced that it intends to amend several regs with respect to chapters 3 (withholding of tax on nonresident aliens and foreign corporations) and 4 (the Foreign Account Tax Compliance Act; FATCA) of the Code to reduce a number of compliance burdens. Prior to the issuance of […]

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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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Regs will ban replacing defined benefit plan lifetime income with lump sum payment

Regs will ban replacing defined benefit plan lifetime income with lump sum payment

Notice 2015-49, 2015-30 IRB IRS has announced that it will amend the required minimum distribution (RMD) regs to provide that qualified defined benefit plans generally are not allowed to replace any joint and survivor, single life, or other annuity that is currently being paid with a lump sum payment or other accelerated form of distribution. […]

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IRS will amend regs to expand mark-to-market exception to PFIC shareholder reporting

IRS will amend regs to expand mark-to-market exception to PFIC shareholder reporting

Notice 2014-51, 2014-40 IRB In a Notice, IRS has announced that it will amend existing regs to provide that taxpayers whose stock in a passive foreign investment company (PFIC) is marked to market under a Code provision other than Code Sec. 1296 are exempt from the standard reporting requirements that apply to PFIC shareholders. Currently, […]

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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