Author: Meadows Collier
Section 2704 Proposed Regulations Identified for Burden Reduction in IRS Report
I last provided an update on the proposed regulations under I.R.C. Section 2704 (the 2704 Proposed Regulations) on January 31, 2017, in which I covered President Trump’s then recent Executive...
MLR Blog Post- U.S. Tax Court Decision Deals Blow to IRS on Taxation of U.S. Partnership Interests Held by Foreign Persons
At last year’s Annual Meadows Collier Tax Conference, my colleague, Stephen Beck, and I discussed some of the more recent hot topics in international tax law. During our discussions, we spoke of the current ambiguity in...
The RESPECT Act: Will Congress Pass Legislation to Limit IRS Civil Forfeiture in “Structuring” Cases?
The RESPECT Act (H.R. 1843), also known as the Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act, was originally introduced in the House of Representatives in March 2017....
The Treasury Targeting the Recent Section 385 Debt-Equity Regulations (and Others) for Potential Repeal
On Friday, July 7th, the U.S. Department of the Treasury (the “Treasury”) announced in Notice 2017-38 that it is targeting eight tax regulations for potential repeal (click here). Included in the eight targeted are the...