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Proposed

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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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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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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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 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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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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Proposed reliance regs set out several requirements for supporting organizations

Proposed reliance regs set out several requirements for supporting organizations

Preamble to Prop Reg02/18/2016; Prop Reg § 1.509(a) – 4 IRS has issued proposed reliance regs that spell out rules for qualifying as a Type III supporting organization and define the term “control” for purposes of rules which prohibit a Type I supporting organization or a Type III supporting organization from accepting contributions from persons […]

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Proposed Regs set ordering rule on limitation on multiemployer plan benefit suspensions

Proposed Regs set ordering rule on limitation on multiemployer plan benefit suspensions

Preamble to Prop Reg 02/09/2016; Prop Reg § 1.432(e)(9)-1 Proposed regs — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014 IRS has issued proposed regs that would provide guidance on the limitation that governs the application of a suspension of benefits under a multiemployer […]

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Proposed Regs would modify nondiscrimination requirements for certain retirement plans

Proposed Regs would modify nondiscrimination requirements for certain retirement plans

Preamble to Prop Reg1/28/2016; Prop Reg § 1.401(a)(4)-2, Prop Reg § 1.401(a)(4)-3, Prop Reg § 1.401(a)(4)-4, Prop Reg § 1.401(a)(4)-8, Prop Reg § 1.401(a)(4)-9 , Prop Reg § 1.401(a)(4)-12 , Prop Reg § 1.401(a)(4)-13 IRS has issued proposed regs that would modify the nondiscrimination requirements applicable to certain retirement plans that provide additional benefits to […]

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Proposed Regs would modify nondiscrimination requirements for closed pension plans

Proposed Regs would modify nondiscrimination requirements for closed pension plans

Preamble to Prop Reg1/28/2016; Prop Reg § 1.401(a)(4)-2, Prop Reg § 1.401(a)(4)-3, Prop Reg § 1.401(a)(4)-4, Prop Reg § 1.401(a)(4)-8, Prop Reg § 1.401(a)(4)-9 , Prop Reg § 1.401(a)(4)-12 , Prop Reg § 1.401(a)(4)-13 IRS has issued proposed regs that would modify the nondiscrimination requirements applicable to certain retirement plans that provide additional benefits to […]

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Proposed reliance regs clarify “normal retirement age” for governmental plans

Proposed reliance regs clarify “normal retirement age” for governmental plans

Preamble to Prop Reg 1/26/2015, Prop Reg § 1.401(a)-1 IRS has issued proposed reliance regs that provide rules on whether the normal retirement age (NRA) under a governmental plan that is a pension plan satisfies the requirements of Code Sec. 401(a) and whether the payment of definitely determinable benefits that commence at the plan’s NRA […]

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Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice 2016-10, 2016-6 IRB In a Notice, IRS has provided guidance with regard to regs it intends to issue on alternative methods that regulated investment companies (RICs) and their shareholders may use to satisfy their obligations under Code Sec. 853 and Code Sec. 905(c) where a RIC receives a refund of a foreign tax that […]

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Proposed Regs Drastically Increase Enrolled Agent Examination Fee

Proposed Regs Drastically Increase Enrolled Agent Examination Fee

Preamble to Prop Reg01/25/2016, Prop Reg § 300.4 Proposed regs on Special Enrollment Examination User Fee for Enrolled Agents. IRS has issued proposed regs that would raise the fee for taking the 3-part enrolled agent special enrollment examination from $11 to $99 per part (i.e., $297 for all three parts). This amount doesn’t include any […]

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Proposed regs would require country-by-country reporting by U.S. parents of large multinational groups

Proposed regs would require country-by-country reporting by U.S. parents of large multinational groups

Preamble to Prop Reg12/21/2015Prop Reg § 1.6038-4 Proposed regulations on Country-by-Country Reporting. IRS has issued proposed regs that would require annual country-by-country (CbC) reporting by U.S. persons that are the ultimate parent entity of a multinational enterprise (MNE) group that has annual revenue for the preceding annual accounting period of $850 million or more. The […]

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Proposed regs cover many spouse relief subjects

Proposed regs cover many spouse relief subjects

Preamble to Prop Reg11/19/2015; Prop Reg § 1.66-1,Prop Reg § 1.66-2, Prop Reg § 1.66-3 , Prop Reg § 1.66-4, Prop Reg § 1.6015-1, Prop Reg § 1.6015-2, Prop Reg § 1.6015-3 , Prop Reg § 1.6015-4, Prop Reg § 1.6015-5, Prop Reg § 1.6015-6 , Prop Reg § 1.6015-7, Prop Reg § 1.6015-8 IRS […]

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Proposed regs implement Supreme Court’s same-sex marriage decision

Proposed regs implement Supreme Court’s same-sex marriage decision

IRS has issued proposed regs that would provide that a marriage of two individuals, whether of the same sex or the opposite sex, will be recognized for federal tax purposes if that marriage is recognized by any State, possession, or territory of the U.S. The regs provide additional clarity on how the federal government will […]

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Proposed regs would significantly alter tax treatment of certain outbound transfers

Preamble to Prop Reg09/14/2015; Prop Reg § 1.367(a)-1, Prop Reg § 1.367(a)-2, Prop Reg § 1.367(a)-3, Prop Reg § 1.367(a)-4, Prop Reg § 1.367(a)-5 , Prop Reg § 1.367(a)-6 , Prop Reg § 1.367(a)-7, Prop Reg § 1.367(a)-8, Prop Reg § 1.367(d)-1, Prop Reg § 1.367(e)-2, Prop Reg § 1.482-1 , Prop Reg § 1.6038B-1 […]

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Proposed regs detail transfer tax on covered gifts and bequests from covered expatriates

Proposed regs detail transfer tax on covered gifts and bequests from covered expatriates

Preamble to Prop Reg 09/09/2015, Prop Reg § 28.2801-1, Prop Reg § 28.2801-2, Prop Reg § 28.2801-3, Prop Reg § 28.2801-4, Prop Reg § 28.2801-5 , Prop Reg § 28.2801-6 , Prop Reg § 28.2801-7 IRS has issued proposed regs on the tax under Code Sec. 2801 on U.S. citizens and residents who receive gifts […]

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IRS offers preview of proposed regs on health insurance coverage reporting

IRS offers preview of proposed regs on health insurance coverage reporting

Notice 2015-68, 2015-41 IRB In a Notice, IRS has advised taxpayers of its intent to issue proposed regs under Code Sec. 6055 that would, among other things, clarify reporting requirements with respect to catastrophic health insurance plans enrolled in through an Exchange and modify the existing “supplemental coverage rule.” The Notice also provides penalty relief […]

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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