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Comments on Regulations

Proposed regs would expand on previous guidance regarding installment obligation dispositions

Proposed regs would expand on previous guidance regarding installment obligation dispositions

Preamble to Prop Reg 12/22/2014; Prop Reg § 1.351-1, Prop Reg § 1.361-1, Prop Reg § 1.453B-1, Prop Reg § 1.721-1 IRS has issued proposed regs that would consolidate and expand upon rules contained in a reg and a revenue ruling on whether the disposition of an installment obligation results in the recognition of gain […]

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Wrap-Around Health Coverage Could Qualify As Excepted Benefits Under Pilot Program

Wrap-Around Health Coverage Could Qualify As Excepted Benefits Under Pilot Program

Preamble to Prop Reg 12/19/2014; Prop Reg § 54.9831-1; Prop Labor Reg 2590.732(c)(3)(vii)   IRS, EBSA, and the Department of Health and Human Services (HHS) (the Departments) have issued new proposed regs that would create a pilot program for allowing plan sponsors in limited circumstances to offer, as excepted benefits, coverage that wraps around certain […]

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Pilot program provides penalty relief for delinquent non-Title I retirement plans

Pilot program provides penalty relief for delinquent non-Title I retirement plans

In Rev Proc 2014-32, 2014-23 IRB, IRS has established a temporary one-year pilot program to provide Code Sec. 6652(e) and Code Sec. 6692 penalty relief for delinquent Form 5500 series filers that aren’t covered under Title I of the Employee Retirement Income Security Act of 1974 (ERISA) – i.e., “one-participant plans” and certain foreign plans. […]

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What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

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What is the value and utility of regs, rulings, and other IRS documents – Part I

What is the value and utility of regs, rulings, and other IRS documents – Part I

IRS issues a widde variety of documents, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This blog will provide an […]

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Time reprieve for when specified equity-linked instruments treated as dividend equivalents

Time reprieve for when specified equity-linked instruments treated as dividend equivalents

In Notice 2014-14, 2014-13 IRB, IRS has announced its intentions to modify the proposed regs on specified equity-linked instruments (specified ELIs) when those regs are finalized. The ELI rules, which originally would have applied to instruments issued after on or after Mar. 5, 2014, will now apply to equity-linked instruments issued on or after 90 […]

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Final, temporary & proposed regulations clarify PFIC owner determinations and filing requirements

Final, temporary & proposed regulations clarify PFIC owner determinations and filing requirements

IRS has issued temporary and proposed regs providing guidance on determining ownership of a passive foreign investment company (PFIC) and the annual filing requirements for shareholders of PFICs. The temporary regs, the text of which serves as the text of the proposed regs, generally adopt portions of proposed regs issued in ’92, as revised to […]

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Proposed regulations would modify basis rules for term interests in CRTs to prevent an abuse

Proposed regulations would modify basis rules for term interests in CRTs to prevent an abuse

IRS has issued proposed regs [Preamble to Prop Reg 01/16/2014; Prop Reg § 1.1014-5] that provide rules for determining a taxable beneficiary’s basis in a term interest in a charitable remainder trust (CRT) upon a sale or other disposition of all interests in the trust to the extent that basis consists of a share of […]

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New final mortgage insurance premium reporting regs apply to 2013 and thereafter

New final mortgage insurance premium reporting regs apply to 2013 and thereafter

In T.D. 9642, 11/26/2013; Reg. § 1.6050H-3, IRS has issued final regs regarding the reporting requirements that apply to persons who receive mortgage insurance premiums. The regs apply only to 2013 and any future years for which the mortgage insurance deduction may apply; there is no reporting requirement for 2012. Background. Under Code Sec. 6050H(h), […]

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Special Study: Navigating the Final Capitalization Regs – Part VII

Special Study: Navigating the Final Capitalization Regs – Part VII

Earllier this year, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. This article, the seventh and final installment of […]

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Special Study: Navigating the Final Capitalization Regs – Part VI

Special Study: Navigating the Final Capitalization Regs – Part VI

Earlier this year, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. This article, the sixth installment of a multi-part […]

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Special Study: Navigating the Final Capitalization Regs – Part V

Special Study: Navigating the Final Capitalization Regs – Part V

Earlier this year, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. This article, the fifth installment of a multi-part […]

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Special Study: Navigating the Final Capitalization Regs – Part IV

Special Study: Navigating the Final Capitalization Regs – Part IV

Earlier this year, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. This article, the fourth installment of a multi-part […]

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Special Study: Navigating the Final Capitalization Regs – Part III

Special Study: Navigating the Final Capitalization Regs – Part III

Earlier this year, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. This article, the third installment of a multi-part […]

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Special Study: Navigating the Final Capitalization Regs – Part II

Special Study: Navigating the Final Capitalization Regs – Part II

In 2013, IRS issued long-awaited final regs on a vast subject of vital interest to millions of taxpayers – the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. This article, the second of a multi-part Special Study, provides in-depth analysis of the de minimis […]

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Special Study: Navigating the Final Capitalization Regs – Part I

Special Study: Navigating the Final Capitalization Regs – Part I

In 2013, IRS issued long-awaited final regs providing guidance on the application of Code Sec. 162(a) and Code Sec. 263(a) to amounts paid to acquire, produce, or improve tangible property. These important new regs will affect virtually all taxpayers that acquire, produce, or improve tangible property. There is much for businesses to be pleased with […]

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Regulations both ease and toughen requirements for suspending 401(k) safe harbor contributions

Regulations both ease and toughen requirements for suspending 401(k) safe harbor contributions

IRS has issued final regulations, T.D. 8641, Reg. § 1.401(k)-3, Reg. § 1.401(m)-3, permitting employers whose 401(k) safe harbor plans provide for nonelective contributions to suspend those contributions under conditions that are easier for employers to meet than those that applied under proposed reliance regs. The final regs also apply these requirements to suspensions of safe […]

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IRS amends applicability date for mixed saddle identification temp regs

IRS amends applicability date for mixed saddle identification temp regs

In response to comments expressing concern about the immediate applicability date for temporary regs relating to identified mixed straddles, IRS has pushed back the applicability date to the date on which the rules are published as final, which it anticipates will be by June 30, 2014. Background. In general, if a taxpayer has held substantially […]

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IRS amends applicability date for mixed straddle identification temporary regulations

IRS amends applicability date for mixed straddle identification temporary regulations

In response to comments expressing concern about the immediate applicability date for temporary regs relating to identified mixed straddles, IRS has pushed back the applicability date to the date on which the rules are published as final, which it anticipates will be by June 30, 2014. Background. In general, if a taxpayer has held substantially […]

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IRS issues final regs on individual mandate’s shared responsibility payment

IRS issues final regs on individual mandate’s shared responsibility payment

IRS issues Final Regs on individual mandate’s shared responsibility payment – T.D. 9632, 08/27/2013; Reg. § 1.5000A-1; Reg. § 1.5000A-2; Reg. § 1.5000A-3; Reg. § 1.5000A-4; Reg. § 1.5000A-5. Click here for the Treasury Department’s “Fact Sheet: Individual Shared Responsibility for Health Insurance Coverage and Minimum Essential Coverage Final Rules. ” IRS has issued 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