By: Amanda Wilson The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically, the IRS may hit pause on these...

By: Amanda Wilson Earlier this year, I posted about the possibility that the NFL may lose its tax exempt status. The NFL has decided instead to give up its tax-exempt status. It has been estimated that the tax-exempt status only saved the NFL about...

By: Amanda Wilson Last week, I was at the ABA Tax Section meeting in DC, and one refrain that I heard over and over is that tax reform is a major priority for Congress. The Obama administration has basically shut down the possibility of personal tax...

By: Amanda Wilson In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax when he/she/it disposes of...