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Temporary

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 IRS has partially withdrawn portions of two sets of proposed regs issued in 2009 and 2014. The withdrawn portion of the 2009 proposed regs no […]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

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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 […]

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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 […]

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Temp regs issued on partnership’s allocation of creditable foreign tax expenditures

Temp regs issued on partnership’s allocation of creditable foreign tax expenditures

T.D. 9748, 02/03/2016, Reg. § 1.704-1T; Preamble to Prop Reg02/03/2016, Prop Reg § 1.704-1 IRS has issued temporary regs on the operation of the safe harbor rule under Reg. § 1.704-1(b)(4)(viii), which is used in determining whether allocations of partnership creditable foreign tax expenditures to partners are deemed to be in accordance with the partners’ […]

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Temporary Regs Outline Participant Vote Requirement For Suspension Of Plan Benefits

Temporary Regs Outline Participant Vote Requirement For Suspension Of Plan Benefits

T.D. 9735, 08/31/2015, Prop Reg § 1.432(e)(9)-1T, Preamble to Prop Reg 08/31/2015, Prop Reg § 1.432(e)(9)-1 Under Code Sec. 432(e)(9), as amended by the Multiemployer Pension Reform Act of 2014, multiemployer defined benefit pension plans in critical and declining status are allowed to reduce the plan benefits payable to participants and beneficiaries (a “suspension of […]

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Temporary Regs Expand Application of Sec. 956 Anti-Avoidance Rule to Partnerships

Temporary Regs Expand Application of Sec. 956 Anti-Avoidance Rule to Partnerships

T.D. 9733, 09/01/2015; Reg. § 1.954-2T, Reg. § 1.956-1T, Reg. § 1.954-2Reg. § 1.956-1 IRS has issued temporary regs that, by expanding the anti-avoidance rule in Reg. § 1.956-1T(b)(4), treat property indirectly held by a controlled foreign corporation (CFC) in connection with certain transactions involving partnerships as “U.S. property”. The temporary regs also provide guidance […]

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Temp regs cover allocation of Sec. 199 wages in short tax year and in acquisition or disposition

Temp regs cover allocation of Sec. 199 wages in short tax year and in acquisition or disposition

T.D. 9731, 08/26/2015, Reg. § 1.199-2, Reg. § 1.199-2T, Reg. § 1.199-8, Reg. § 1.199-8T IRS has issued temporary regs that provide guidance for purposes of the Code Sec. 199 domestic production activities deduction (DPAD) on the allocation of W-2 wages paid by two or more taxpayers that are employers of the same employees during […]

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To combat fraud, temp and proposed regs will end automatic information return extensions

To combat fraud, temp and proposed regs will end automatic information return extensions

T.D. 9730, 08/12/2015; Reg. § 1.6081-8T; Preamble to Prop Reg 08/12/2015; Prop Reg § 1.6081-8 IRS has issued temporary regs that end the availability of automatic extensions for filing forms in the W-2 series (except Form W-2G), effective for returns due after Dec. 31, 2016. It has also issued proposed regs that would end the […]

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Correction narrows scope of recently-issued regs that close corporate partner loophole

Correction narrows scope of recently-issued regs that close corporate partner loophole

IRS has corrected temporary regs that were issued June 12, 2015, that prevent a corporate partner from avoiding corporate-level gain through transactions with a partnership involving equity interests of the partner. The correction somewhat narrows the scope of the regs.  Click here for TD 9722, Partnership Transactions Involving Equity Interests of a Partner, as corrected. […]

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Guidance on certain multiemployer DB plans applying for suspension of benefits

Guidance on certain multiemployer DB plans applying for suspension of benefits

T.D. 9723, 06/17/2015, Reg. § 1.432(e)(9)-1T, Preamble to Prop Reg06/17/2015, Prop Reg § 1.432(e)(9)-1 , Rev Proc 2015-34, 2015-26 IRB Contemporaneously, IRS has released temporary regs, proposed regs, and a revenue procedure to provide guidance to multiemployer defined benefit pension plans in critical and declining status, on how to apply for approval of a proposed […]

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Regs delay effective date of certain reporting by brokers on debt instrument transfers

Regs delay effective date of certain reporting by brokers on debt instrument transfers

T.D. 9713, 06/04/2015; Reg. § 1.6045A-1T IRS has amended recently issued temporary regs on certain information reporting by brokers on transfers of debt instruments. The amendment postpones the date for reporting certain information on a transfer statement six months, from June 30, 2015, to Jan. 1, 2016. Background. Code Sec. 6045A requires a broker transferring […]

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Temporary Regs spell out treatment of nonperiodic payments under notional principal contracts

Temporary Regs spell out treatment of nonperiodic payments under notional principal contracts

T.D. 9719, 05/07/2015, Reg. § 1.446-3, Reg. § 1.446-3T, Reg. § 1.956-2T, Preamble to Prop Reg 05/07/2015, Prop Reg § 1.446-3   IRS has issued temporary regs under Code Sec. 446 providing that, subject to two exceptions, a notional principal contract (NCP) with a nonperiodic payment—regardless of whether it is significant—must be treated as two […]

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Temporary Regs on allocation of controlled groups’ research credits follow 2013 notice

Temporary Regs on allocation of controlled groups’ research credits follow 2013 notice

T.D. 9717, 04/02/2015; Reg. § 1.41-0, Reg. § 1.41-6, Reg. § 1.41-6T , Reg. § 1.45G-0, Reg. § 1.45G-1, Reg. § 1.45G-1T , Reg. § 1.280C-4, Reg. § 1.280C-4T; Preamble to Prop Reg04/02/2015; Prop Reg § 1.41-6 , Prop Reg § 1.45G-1, Prop Reg § 1.280C-4 IRS has issued temporary regs which provide rules for […]

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Regs On Reporting By Brokers Of Basis Amounts And Of Broker-To-Broker Transfers

Regs On Reporting By Brokers Of Basis Amounts And Of Broker-To-Broker Transfers

T.D. 9713, 03/12/2015; Reg. § 1.6045-1, Reg. § 1.6045-1T, Reg. § 1.6045A-1 , Reg. § 1.6045A-1T; Preamble to Prop Reg03/12/2015; Prop Reg § 1.6045-1, Prop Reg § 1.6045A-1 IRS has issued final and temporary regs that update final 2013 regs on reporting by brokers of basis amounts and of broker-to-broker transfers. The text of the […]

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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