Gabby Hirz, a senior attorney in the Tax Controversy Group discusses one of the most notable decisions of third quarter 2017, Grecian Magnesite Mining v Commissioner of Internal Revenue, with Rom Watson, a partner in the Tax Group and co-head of the firm’s International practice group.  Grecian Magnesite Mining considered whether a foreign corporation’s proceeds... Continue Reading
In Palmolive Building Investors, LLC v. Commissioner, 149 T.C. No. 18, the Tax Court denied a charitable contribution deduction of a donated façade easement because the easement deed failed to satisfy the perpetuity requirement of section 170. Background – Perpetuity Requirement A contribution of a qualified real property interest is deductible as a qualified conservation...Continue Reading…
The IRS announced that whistleblower awards paid under section 7623 on or after October 1, 2017 and on or before September 30, 2018, will continue to be reduced by the “sequestration reduction rate”, which has now been lowered slightly to 6.6 percent. The 6.6 percent fiscal 2018 sequestration reduction rate represents a .3 percent decrease from fiscal 2017’s 6.9 percent. The sequestration reduction will unfortunately continue to be applied to whistleblower payments unless and until a law is enacted that cancels or changes the sequester or a court decides that it is improper.
On October 4, 2017, the US Department of the Treasury (Treasury) announced that it would withdraw more than 200 regulations, including the proposed regulations under Internal Revenue Code (Code) Section 2704. The announcement is part of President Trump’s initiative to lessen the regulatory burden on taxpayers due to excessive regulations. In a press statement, Treasury... Continue Reading
Finally:  Withdrawal of the Political Subdivision Regulations Is Announced The eagerly awaited verdict on the proposed political subdivision regulations (Proposed Political Subdivision Regulations) (“Proposed Regulations”) is finally in and their withdrawal has been announced.  These regulations have been a frequent subject of our posts (here,  here, here, here, here, and here) Treasury issued its interim Report on June 22, 2017 (here) under Executive Order … Continue Reading