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Tax Planning Internal Revenue Service Disclosure Requirements

Gray Reed

IRS Targets Charitable Remainder Annuity Trusts (CRATs) as Listed Transactions

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On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions.  For those unaware of the listed transaction rules, such a designation would...more

Freeman Law

Correction to APA Non-Compliance | IRS Issues Proposed Regulations for Syndicated Conservation Easements

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On December 6th, the IRS proposed regulations (and comment period for same) that would require participants and promoters of syndicated conservation easement transactions to make certain disclosures relating conservation...more

Freeman Law

Extended Tax Filing Deadline | Commonly Overlooked Tax Disclosures

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This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more

Freeman Law

The Art of the Tax Disclosure: How to Avoid Tax Penalties By Disclosing a Return Position

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There are at least three questions when it comes to IRS tax disclosures: (1) Should a taxpayer disclose; (2) How should a taxpayer disclose; and (3) How much detail should be disclosed? Should a taxpayer simply append a...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Mayer Brown

The Taxpayer First Act and the Impact on Secondary Market Participants

Mayer Brown on

The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019.  The Act is designed, among other things, to overhaul and modernize...more

Jones Day

Paradise Papers: The Latest Offshore Leak

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Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

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