Articles by Grant Solomon
Treasury and IRS issue final rules relating to repatriation of IP
On October 9, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”), which, in certain cases, terminate the continued application of Section 367(d) of the Internal Revenue Code (the “Code”) from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to certain U.S. persons. Background.
Treasury and IRS Issue Long Awaited Proposed Regulations on the Corporate Alternative Minimum Tax
On September 12, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG 112129-23, RIN 1545-BQ84) (the “Proposed Regulations”) providing much needed guidance on the application of the corporate alternative minimum tax (“CAMT”).
Easy as ABC - IRS Issues Final Rules Aimed at Stymieing Killer Bs
On July 17, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations under Section 367(b) of the Internal Revenue Code (the “Code”) that provide guidance applicable to: the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to those reorganizations; and...
Final Regulations: Guidance on Reporting and Payment of Excise Tax
On June 28, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (T.D. 10002) (the “Final Regulations”) that provide guidance applicable to the reporting and payment of the excise tax under section 4501 of the Internal Revenue Code of 1986, as amended (the “Code”), on repurchases of corporate stock after December 31, 2022 (the “Excise Tax”) The Final Regulations adopt, without significant modification, one set of proposed...
Clear as Mud - Chevron Irreverence and Tax Law
In a 6-3 decision written by Chief Justice Roberts, the Supreme Court in Loper Bright Enterprises v. Raimondo overturned the Court’s decision in Chevron v.
Updated Procedures for Section 355 Private Letter Rulings: Rev. Proc. 2024-24 and Notice 2024-38
On May 1, 2024, the Treasury Department and Internal Revenue Service (the “Treasury” and “IRS,” respectively) issued Revenue Procedure (“Rev. Proc.”) 2024-24 and Notice 2024-38 (collectively, the “Guidance”). The Rev. Proc.
Here We Go - Excise Tax Proposed Regulations Largely “NSYNC” with Notice 2023-2
On April 9, 2024, the Treasury Department (the “Treasury”) and Internal Revenue Service (the “IRS”) two sets of proposed regulations (the “Proposed Regulations”) regarding the application of the section 4501 excise tax on repurchases of corporate stock (the “Excise Tax”) and the reporting and payment of such taxes. The Proposed Regulations generally follow the approach of Notice 2023-2 (the “Notice”), which was issued on Dec. 27, 2022, with some clarifications and modifications.
Killer Bs Get Stung - IRS Issues Proposed Rules Aimed at Triangular Reorganizations and Inbound Non-recognition Transactions
On October 5, 2023, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued long awaited proposed regulations under Section 367(b) of the Internal Revenue Code (the “Code”) providing guidance on the use of property to acquire parent stock or securities in connection with certain cross border triangular reorganizations, colloquially referred to as ‘Killer B’ transactions (the “Proposed Regulations”).
IP Phone Home - IRS Issues New Proposed Rules on the Repatriation of Intangible Property
Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation.
State of the Union: President Biden Calls for Increase to the Excise Tax
The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. Much welcome guidance was released on December 27, 2022 in Notice 2023-2 (the “Notice”), which provides taxpayers with interim guidance until proposed regulations are issued.
A Disgusting Review of San Diego’s Finest Kitchen – Lomabeat.com
| October 6, 2022 | Restaurants | Let’s face it: Point Loma Nazarene University’s cafeteria is far too often mediocre. Chances are your last meal came from there. Was it nutritious? Certainly. Was it appetizing? potentially In San Diego County, one of the most diverse and exciting parts of California, you can discover a wealth of delicious food from around the world.
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