2016-Issue 4 – In past articles, we have discussed the increased corporate interest in unlocking shareholder value via real estate investment trust (REIT) conversion transactions (see “REIT Conversions – A Primer on Key Business and Tax…

2016-Issue 3 – Over the last year, the energy sector has been plagued with low commodity prices. The plunge in crude oil and natural gas prices has in many cases shaved over 50 percent off stock prices of many exploration and production (E&P)…

2016-Issue 2 – We have been dealing with a lot of aggressive auditors lately — not just aggressive from the standpoint of inflexibility on audit assessments, but aggressive in seeking to dictate the terms of how the audit is going to be managed from…

2016-Issue 1 – Given the volatility we have experienced in the financial markets, many would-be acquirers are understandably wary of taking on defined benefit pension plan risk. This is a risk that no one is eager to take on and that some…

2015-Issue 42 — The second half of 2015 has been a busy period for partnership taxation. The Treasury issued proposed regulations under the long reserved IRC Section 1.707-2, and Congress passed a new law governing how large partnership audits will…

2015-Issue 41—Eight years ago, the IRS announced it intended to provide additional regulatory guidance on Internal Revenue Code (IRC) Section 457(f) (IRS Rev. Bull. 2007-32). Section 457(f) applies to nonqualified deferred compensation plans of…

2015-Issue 41—Eight years ago, the IRS announced it intended to provide additional regulatory guidance on Internal Revenue Code (IRC) Section 457(f) (IRS Rev. Bull. 2007-32). Section 457(f) applies to nonqualified deferred compensation plans of…

2015-Issue 40—The year is drawing to a close, and many people are making holiday plans for visiting with family, decorating and buying holiday gifts. Along with all this spirited cheer, there is another important consideration on the horizon: your…

2015-Issue 38—In May 2014, in an effort to align standards, the FASB (Financial Accounting Standards Board) and IASB (International Accounting Standards Board) issued final standards on revenue recognition. These final standards were the product of…

2015-Issue 37—“Wow, this seems like a great company. I’m going to spend millions of dollars to acquire it without performing any basic due diligence to determine whether I’m inheriting any unrecorded liabilities that will diminish its future value.…

2015-Issue 37—“Wow, this seems like a great company. I’m going to spend millions of dollars to acquire it without performing any basic due diligence to determine whether I’m inheriting any unrecorded liabilities that will diminish its future value.…

2015-Issue 36—At the recent meeting of the G20 nations’ finance ministers and central bank governors, the ministers announced their support for the remaining base erosion and profit-shifting (BEPS) initiatives published on October 5 by the…

2015-Issue 35—Some of you may have heard that on July 31, 2015, President Obama signed a bill into law that allowed for a short-term extension of mass transit and highway funding: the Surface Transportation and Veterans Health Care Choice…

2015-Issue 34—On September 14, 2015, the Department of the Treasury and the Internal Revenue Service released proposed regulations under Section 367 that would dramatically change the treatment of goodwill and going concern value transferred by a U.…

2015-Issue 33—This past summer, you probably noticed a significant number of both business and tax publications discussing “patent boxes.” Your initial reactions were likely, “what is a patent box?” and “how would it impact my company?” Hopefully,…

2015-Issue 32 – Although their efforts have been highly politicized and trumpeted in the press as of late, U.S. multinationals have for years sought and implemented various planning techniques to lower their overall corporate effective tax…

2015-Issue 31—On July 23, 2015, the Internal Revenue Service issued proposed regulations under Section 707(a)(2)(A) that could have broad implications for how a partnership can structure a valid “profits interest.” The preamble to these proposed…

2015-Issue 30—Many companies maintain “top hat” plans to provide supplemental pension benefits to their top-paid employees. A recent brief filed by the Secretary of Labor in pending litigation suggests that sponsors of such plans may want to rethink…

2015-Issue 29—Starting this fall, nine states are instituting tax amnesty programs for reporting unpaid taxes. States view this as an opportunity to increase tax collections without the political perils of changing tax laws. While tax amnesties are…

2015-Issue 28—In a pair of rulings issued recently, the IRS announced some significant changes impacting qualified retirement plans. Notice 2015-49 would prohibit the now-common practice of allowing annuitants in pay status to elect to receive their…