Tax

Category: Uncategorized

  • Federal Income Tax Documents

    Federal Income Tax Documents Federal Tax Research: Documents and Resources The following entry describes the main types of federal income tax documents and indicates the most common resources for locating them. This section comprises: The Internal Revenue Code (IRC) The Treasury Regulations (Treas.Reg.) IRS Rulings and Pronouncements Tax Court Decisions Internal Revenue Code (IRC) Federal tax…

  • Hedge Funds

    Hedge Funds Tax Aspects of Hedge Funds This section examines the special tax issues affecting the general partner and its members; foreign and tax exempt investors; and U.S. individuals. Highlights of the section include a detailed description and analysis of the use of the partnership form by most hedge funds, incentive allocations and fee deferrals…

  • Employer Comparable Contributions

    Employer Comparable Contributions to Health Savings Accounts under Section 4980G AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains final regulations that provide guidance regarding employer comparable contributions to Health Savings Accounts HSAs) under section 4980G. In general, these final regulations affect employers that contribute to employees’ HSAs. DATES: Effective Date:…

  • Cooperative

    Cooperative Taxation of Cooperatives and their Patrons The issue should analyze the federal income tax treatment of cooperatives and their patrons under subchapter T of Chapter 1, Subtitle A, of the Internal Revenue Code. A cooperative is a business format in which patrons of the cooperative join together to transact business collectively. The two general…

  • Internal Revenue Notice 2004-25

    Internal Revenue Notice 2004-25 — Health Savings Accounts Part III – Administrative, Procedural, and Miscellaneous PURPOSE This notice provides transition relief for calendar year 2004 for eligible individuals who establish an HSA or on before April 15, 2005 from the requirement that qualified medical expenses may only be paid or reimbursed by an HSA if…

  • Durable Powers of Attorney

    Durable Powers of Attorney By Andrew H. Hook, Esq. Oast & Hook, P.C., Virginia Beach and Portsmouth, VA Durable powers of attorney (DPAs) are extremely complex, powerful, and flexible legal instruments that create significant legal authority, duties, and obligations. The scope of the power of attorney, as well as its provisions, should be tailored to…

  • Internal Revenue Notice 2004-50

    Internal Revenue Notice 2004-50 — Health Savings Accounts Part III – Administrative, Procedural, and Miscellaneous PURPOSE This notice provides guidance on Health Savings Accounts. BACKGROUND Section 1201 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003, Pub. L. No. 108-173, added section 223 to the Internal Revenue Code to permit eligible individuals to…

  • Indirect Foreign Tax Credits

    Indirect Foreign Tax Credits Under §902, a domestic corporation may be deemed to have paid, for purposes of the §901 foreign tax credit, foreign income taxes paid by a foreign corporation from which the domestic corporate shareholder receives a dividend. It is also relevant the analysis of §960, under which a domestic corporation that is…

  • NatWest Case

    NatWest Case By Willard B. Taylor, Esq. Sullivan & Cromwell LLP, New York, N.Y. In National Westminster Bank, PLC v. U.S.1 (hereafter, “NatWest”), decided on January 15, 2008, the Court of Appeals for the Federal Circuit, seemingly ending years of litigation, affirmed decisions of the Claims Court which had held that it would be inconsistent…

  • Internal Revenue Notice 2004-23

    Internal Revenue Notice 2004-23 — Health Savings Accounts This notice provides a safe harbor for preventive care benefits allowed to be provided by a high deductible health plan (HDHP) without satisfying the minimum deductible under section 223(c)(2) of the Internal Revenue Code. BACKGROUND Section 1201 of the Medicare Prescription Drug, Improvement, and Modernization Act of…