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Internal Revenue Service Contract Terms

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Seward & Kissel LLP

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

Seward & Kissel LLP on

Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

Kohrman Jackson & Krantz LLP

Supreme Court Decision in Connelly v. US: Implications for Family-Owned Businesses

In a landmark decision, the U.S. Supreme Court’s decision in Connelly v. United States will require closely-held business owners to reconsider their current buy-sell arrangement in order to avoid additional federal estate...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2024

On March 27, 2024 the Vermont Captive Insurance Association (VCIA) held its biannual “Roadshow” educational event designed for prospective captive insurance companies. The Roadshow, which has been hosted in over 20 cities,...more

Lathrop GPM

Federal Trade Commission Non-Compete Clause Rule May Exempt Certain Nonprofit and Other Types of Employers

Lathrop GPM on

As covered in an earlier client alert by our firm, The Federal Trade Commission (FTC)’s final Non-Complete Clause Rule—if it survives legal challenges and becomes effective—would ban most post-employment non-compete...more

Venable LLP

Earnouts and Their Tax Treatment

Venable LLP on

As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

BakerHostetler

Employers Beware: Broad Confidentiality and Severance Clauses May Violate Whistleblower Protection Laws

BakerHostetler on

Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error. Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more

Foley & Lardner LLP

Empty Promises: Contractual Modification Without Consideration Leaves Franchisee Without Recourse

Foley & Lardner LLP on

Contractual deadline extensions are doled out as a matter of course—and as a matter of courtesy—every day. This is especially the case when the parties are involved in a long-term business relationship, which is frequently...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Trends in Executive Compensation, Employment Law and Compensation Committee Practices

On January 29, 2020, Skadden hosted the webinar “Key Trends in Executive Compensation, Employment Law and Compensation Committee Practices” presented by panelists Michael Bergmann, Executive Compensation and Benefits counsel;...more

Hogan Lovells

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Hogan Lovells on

Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more

Rosenberg Martin Greenberg LLP

Can a Prenuptial Agreement Executed Before January 1, 2019 Preserve Deductibility of Alimony Payments Relating to Divorce Decrees...

The Tax Cuts and Jobs Act of 2017 (“TCJA”) did away with the long-standing provision allowing for deductions of alimony payments by the payor. Specifically, the TCJA adopted the prior definition of “alimony and separate...more

Snell & Wilmer

The IRS’ Initial 162(m) Transition Guidance is Finally Here

Snell & Wilmer on

On August 21, 2018, the IRS released Notice 2018-68 (“Notice”) providing its initial guidance on the Tax Cuts and Jobs Act (“Act”) transition rule for changes made to Section 162(m) of the Internal Revenue Code of 1986, as...more

Polsinelli

IRS Guidelines Provide Greater Flexibility to Nonprofit Borrowers

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New guidelines from the Internal Revenue Service substantially overhaul safe harbors that have existed for 20 years. Specifically, the IRS recently released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”), which establishes...more

Dickinson Wright

IRS Issues New Guidelines for Qualified Management Contracts for Facilities Financed with Tax Exempt Bonds

Dickinson Wright on

Health care providers with facilities financed with tax exempt bonds need to be aware of recent changes to the IRS rules for qualified management contracts. On August 22, 2016, the IRS issued Rev. Proc. 2016-44 which...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Forfeitures can be a compliance headache

Defined contribution plans such as 401(k) plans have a forfeiture provision if there are contribution in the plan that are not immediately vested. The problem with the forfeiture provision is that they are usually neglected...more

Roetzel & Andress

IRS Eases Safe Harbor Conditions Under Which a Contract with a Hospital Will Not Result in Private Business Use of Tax-Exempt...

Roetzel & Andress on

Under federal income tax law, the tax-exempt status of a bond is jeopardized if the proceeds of the bond are used for a private business use. Because hospital facilities are often financed with tax-exempt bonds, hospital...more

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