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...

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...

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:

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...