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Chief Counsel Advice Memorandum Released on Options on Basket of Hedge Funds
Dec 15, 2015
Chief Counsel Advice Memorandum's provide a strong indication of the IRS view on an issue such as options on basket of hedge funds. IRS CCA 201547004 concerns the federal income tax treatment of a taxpayer entering into an 'option' contract on a basket of U.S. and non-U.S. hedge funds.
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IRS Expands Ability to Make Mid-Year Amendments to Safe-Harbor Retirement Plans
Apr 12, 2016
Plan sponsors wishing to make mid-year changes to their plans must be vigilant with respect to the rules for updating the safe-harbor notice to plan participants, as well as seeking professional advice regarding any mid-year modifications.
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Federal Income Tax Treatment of OTC Foreign Currency Options Altered by Sixth Circuit
Jan 22, 2016
Federal income tax treatment of OTC Foreign Currency Options was altered by the 6th Circuit. In Wright, the appeals court held that IRC Sec. 1256(g)(2)(A), OTC foreign currency options are Section 1256 contracts, and, accordingly, are subject to mark-to-market accounting.
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Managers Can Avoid the Danger of Sloppy Valuation Practices
Feb 26, 2016
2016-02-26 By Michael Aronow and Craig Ter Boss Michael Aronow is a partner and Craig Ter Boss is a principal in EisnerAmper’s Corporate Finance Group, specializing in valuation services for alternative asset managers. The recent increase in regulatory scrutiny regarding how asset managers value i
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Congress Makes Permanent 100% Gain Exclusion on Qualified Small Business Stock
Mar 1, 2016
The Qualified Small Business Stock exclusion, also known as the Section 1202 exclusion, is a benefit that C corporations have over other entity types.
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Nov 10, 2015
Understanding the nature of reimbursement fraud and improving controls can help prevent and detect these costly schemes. In 13.8% of all asset misappropriation cases reported, employee reimbursement frauds were present. Here are the types of expense reimbursement fraud.
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2018 Personal Tax Guide - 2017 Year-End Tax Planning Tips
Dec 1, 2017
Effective tax planning can reduce estate taxes, maximize the amount of funds available for retirement, reduce the cost of financing your children's education and assist you in managing your cash flow to help you meet your financial objectives.
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Dec 6, 2017
This is a further comparison of the provisions contained in the House and Senate Finance Committee versions of tax reform legislation. What follows are highlights and a comparison of the individual provisions of these two approaches to tax reform.
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Five Key Year-End Tax Considerations
Dec 7, 2017
As 2017 winds down, tax professionals, chief financial officers, and corporate officials should carefully analyze their year-end tax positions to plan for 2018 and beyond. Here are five major areas of concern that every business should consider.
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Four Year-End International Tax Tips for Multinational Companies
Dec 6, 2017
In addition to managing the usual end-of-year planning considerations, multinational corporations this year have to contend with the added dimension of tax reform. Here are several key topics multinational corporations should consider.
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IRS Identifies Additional Large Business and International Division Audit Campaigns
Dec 4, 2017
Earlier this year, we reported on the IRS Large Business and International (LB&I) division’s announcement of its initial set of 13 campaigns under its new audit approach. On November 3, the IRS identified 11 additional campaigns (with more to come).
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Senate Tax Proposal Would Reverse Tax Court Holding in Grecian Magnesite Case
Nov 16, 2017
Effective for transactions after November 27, 2017 a Senate tax proposal would override the holding in Grecian Magnesite and imposes a 10% withholding tax on the amount realized on the sale or exchange of an interest in a partnership.
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Business Tax Quarterly Executive Summary - Fall 2017
Dec 7, 2017
Year-end tax planning is a linchpin of the business strategy of any company. In this issue of Business Tax Quarterly, we offer some high-level guidance designed to help consider tax consequences and opportunities in both the U.S. and abroad.
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Tax Cuts and Jobs Act Addresses Prepayment of Taxes
Dec 18, 2017
Under the provisions of the new tax law, an individual may not claim an itemized deduction in 2017 on a pre-payment of income tax for a future taxable year in order to avoid the dollar limitation applicable for taxable years beginning after 2017.
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Business Tax Quarterly - Fall 2017 - Suggested Reading
Dec 5, 2017
In this issue of Business Tax Quarterly, we provide resources for learning more about revenue recognition changes, BEPS country-by-country reporting, FATCA and the Senate Tax Bill.
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Business Provisions Further Update: Tax Reform Moves Forward – Comparison of House and Senate Bills
Dec 7, 2017
The Senate passed its version of the Tax Cuts and Jobs Act early in the morning on December 2, 2017.
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A Further Discussion of the Business Provisions in the House Republicans’ Tax Bill
Nov 8, 2017
As previously discussed, the House Republicans released their tax reform bill. At the present time, the House Ways and Means Committee is marking up this bill. The following is a more in-depth discussion of the bill’s business provisions.
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House Republicans Release Tax Reform Bill
Nov 3, 2017
The House Republicans released their long-awaited tax reform bill. The bill’s release is the first step in a multi-step process and many changes, some no doubt quite significant, will be made to this legislation.
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Update: Impact of Proposed Tax Reform on Financial Statements and Effective Tax Rates
Dec 6, 2017
The House Ways and Means Committee has released a tax reform bill and the prospects for tax reform are becoming closer to reality. Companies should begin to consider how tax reform could affect their financial statements and effective tax rates.
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Tax Relief Available to Hurricanes Harvey, Irma and Maria Victims Under the Disaster Tax Relief Act
Oct 26, 2017
In the aftermath of Hurricanes Harvey, Irma and Maria, President Trump signed into law the Disaster Tax Relief Act, providing some relief to individuals and businesses located in federally declared disaster areas who satisfy certain qualifications.