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Proposed Regs Shutdown Exception for Offshore Transfers of Foreign Goodwill

By Amanda Wilson on Sep 15, 2015 in International, IRS, treasury

By: Amanda Wilson Yesterday, the IRS and Treasury released proposed regulations governing the treatment of certain transfers of foreign goodwill and going concern value. When a U.S. person contributes property to a foreign corporation, Section 367...

Further Crackdown on Offshore Corporations

By Amanda Wilson on Sep 2, 2015 in Foreign Operations, International, IRS, Partnership Tax, treasury

By: Amanda Wilson In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...

Upcoming Partnership Tax Webinar

By Amanda Wilson on Sep 1, 2015 in Other, code, International, IRS, Partnership Tax, targeted allocations

By: Amanda Wilson Tomorrow I will be participating in a webinar dealing with Section 704 - partnership allocations. If you are interested in attending, more information can be found here:

IRS Admits Security Breach More Extensive

By Amanda Wilson on Aug 17, 2015 in Other

By: Amanda Wilson Earlier this year, the IRS announced that identity thieves had been able to hack one of its computer databases and gain access to extremely sensitive data. Back then, the IRS indicated that about 225,000 households had been...