Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Final

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 […]

Read the full article →

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 […]

Read the full article →

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 […]

Read the full article →

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 […]

Read the full article →

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 […]

Read the full article →

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; […]

Read the full article →

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 […]

Read the full article →

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 […]

Read the full article →

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. […]

Read the full article →

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 […]

Read the full article →

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 […]

Read the full article →

Regs & revenue procedure cover monitoring duties for low-income housing credit

Regs & revenue procedure cover monitoring duties for low-income housing credit

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 […]

Read the full article →

Regs incorporate PATH Act changes to dispositions of foreign investments in U.S. real property

Regs incorporate PATH Act changes to dispositions of foreign investments in U.S. real property

T.D. 9751, 02/17/2016, Reg. § 1.897-2, Reg. § 1.897-3, Reg. § 1.445-1, Reg. § 1.1445-2, Reg. § 1.1445-3, Reg. § 1.1445-4 , Reg. § 1.1445-5, Reg. § 1.1445-6 , Reg. § 1.1445-11T TD 9751: PATH Act Changes to Section 1445. IRS has issued final and temporary regs that reflect changes made by the Protecting Americans […]

Read the full article →

Final regs cover broker reporting on debt instruments & on OID on tax-exempt obligations

Final regs cover broker reporting on debt instruments & on OID on tax-exempt obligations

T.D. 9750, 02/17/2016, Reg. § 1.6045-1, Reg. § 1.6045A-1, Reg. § 1.6049-10 IRS has issued final regs that provide guidance on information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer’s adjusted basis […]

Read the full article →

Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

TD 9751: PATH Act Changes to Section 1445. IRS has issued final and temporary regs on the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests (USRPIs); the regs reflect changes made by the Protecting Americans from Tax Hikes Act of 2015 (the PATH […]

Read the full article →

Regs set distribution amount for non-functionally integrated Type III supporting organizations

Regs set distribution amount for non-functionally integrated Type III supporting organizations

T.D. 9746, 12/21/2015, Reg. § 1.509(a)-4 IRS has issued final regs that set out the amount that a non-functionally integrated (NFI) Type III supporting organization must annually distribute to its supported organizations. The regs reflect changes to the law made by the Pension Protection Act of 2006 (PPA). Background. Tax-exempt charitable organizations that are private foundations […]

Read the full article →

IRS issues final regs on non-functionally integrated Type III supporting organizations

IRS issues final regs on non-functionally integrated Type III supporting organizations

T.D. 9746, 12/21/2015, Reg. § 1.509(a)-4 Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated. IRS has issued final regs on the distribution requirement for non-functionally integrated (NFI) Type III supporting organizations. The regs reflect changes to the law made by the Pension Protection Act of 2006 (PPA). Background. The PPA directed the […]

Read the full article →

Capitalization regs’ de minimis safe harbor for taxpayers with no AFS raised to $2,500

Capitalization regs’ de minimis safe harbor for taxpayers with no AFS raised to $2,500

Notice 2015-82, 2015-50 IRB; IR 2015-133 In a Notice and accompanying news release, IRS has announced an increase, from $500 to $2,500, in the de minimis safe harbor limit in Reg. § 1.263(a)-1(f)(1)(ii)(D) for taxpayers that don’t maintain an applicable financial statement (AFS). According to IRS, this change will simply the paperwork and recordkeeping requirements […]

Read the full article →

Final regs allow plan amendments to comply with market rate of return requirements

Final regs allow plan amendments to comply with market rate of return requirements

T.D. 9743, 11/13/2015, Reg. § 1.411(a)(13)-1, Reg. § 1.411(b)(5)-1 IRS has issued final regs that allow a plan sponsor of an applicable defined benefit plan that doesn’t comply with the market rate of return requirement, to amend the plan in order to change to an interest crediting rate that is allowed under the previously issued […]

Read the full article →

Final regs on various aspects of the definition of “private activity bond”

Final regs on various aspects of the definition of “private activity bond”

T.D. 9741, 10/26/2015; Reg. § 1.141-1, Reg. § 1.141-3, Reg. § 1.141-6, Reg. § 1.141-12 , Reg. § 1.141-13, Reg. § 1.141-15, Reg. § 1.145-2, Reg. § 1.150-5 IRS has issued final regs that provide State and local governmental issuers of tax-exempt bonds with guidance for applying the private activity bond restrictions. The regs clarify […]

Read the full article →
Page 1 of 7123...Last »
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