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IRS PLR: Extension of Time Granted to Change Accounting Period (IRC §9100)
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Treasury Regulation Section 301.9100 regarding extensions of time to change an accounting period for federal income tax purposes. [PLR 202419014]
IRS PLR: Extension of Time Granted to Make Qualified Subchapter S Trust Election (IRC §1362)
Bloomberg Law· 6 days agoThe IRS has published a private letter ruling on Section 1362 regarding the extension of time to make a qualified subchapter S trust election for federal tax purposes. [PLR 202418003] ...
IRS PLR: Failure to Identify Interest Rate Cap as Hedging Transaction an Inadvertent Error (IRC...
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Section 856 and Treasury Regulations Section 1.1221-2 regarding the taxpayer’s failure to identify an interest rate cap as a hedging transaction ...
IRS PLR: Substitute Mortality Tables for Actuarial Assumptions in Retirement Plans Approved (IRC...
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Section 430, granting the taxpayer’s request to use base substitute mortality tables for making computations for actuarial assumptions in retirement plans, ...
IRS PLR: Private Foundation Set Aside Request for Construction Project Approved (IRC §4942)
Bloomberg Law· 2 days agoThe IRS has published a private letter ruling on Section 4942, granting the taxpayer’s set-aside request. The taxpayer, a tax-exempt private foundation formed under a trust agreement and operating exclusively ...
IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments | JD Supra
JD Supra· 4 days agoThe IRS ruled that the normalization rules precluded the reduction of the NOLC by reason of the TAA payments. Because the regulatory authority required the reduction of the NOLC, the restoration ...
Treasury and the IRS Finalize Section 897 ‘Domestically Controlled’ Look-Through Rule | JD Supra
JD Supra· 7 days agoOn April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 ( ...
IRS Issues New Regs on GST Allocations
WealthManagement.com· 4 days agoTaxpayers must apply for a private letter ruling to get an extension.
Mastering Automated Privilege Logging: How Litigants Can Maximize Efficiency and Limit Expense | JD...
JD Supra· 6 days agoPrivilege logging is one of the most time-consuming, expensive, and contentious components of discovery. Federal Rule of Civil Procedure 26(b)(5)(A),...