Tax

Category: Uncategorized

  • Internal Revenue Procedure 2004-22

    Internal Revenue Procedure 2004-22 — Health Savings Accounts Administrative, Procedural, and Miscellaneous Section 223: Health Savings Accounts SECTION 1. PURPOSE This revenue procedure provides transition relief from Revenue Ruling 2004-38 for determining an “eligible individual” under section 223 who may make contributions to a Health Savings Account (HSA). The transition relief covers the months before…

  • Cash D Reorganizations

    Cash D Reorganizations Cash D Reorganizations–Selected International Issues By Lowell D. Yoder, Esq. McDermott Will & Emery LLP, Chicago, IL Cash D Reorganizations–Selected International Issues By Lowell D. Yoder, Esq. McDermott Will & Emery LLP, Chicago, IL A U.S. multinational may restructure its foreign subsidiaries through asset reorganizations to achieve certain business objectives, such as…

  • Discrimination in Employee Benefit Plans

    Discrimination in Employee Benefit Plans Age, Sex and Disability Discrimination in Employee Benefit Plans By William J. Flanagan, Esq. Crowell & Moring LLP, Washington, DC The diversification of the American workplace presents special issues in the field of employee benefits. Employers that in the past had to worry primarily about the application of the Internal…

  • Qualified Intermediary Program

    Qualified Intermediary Program In Defense of the Qualified Intermediary Program By Edward Tanenbaum, Esq. Alston & Bird LLP, New York, NY On January 25, 2008, the United States Government Accountability Office issued a report (the “Report”), entitled “Tax Compliance–Qualified Intermediary Program Provides Some Assurance That Taxes on Foreign Investors Are Withheld and Reported, but Can…

  • Exempt Organizations

    Exempt Organizations Limited Liability Companies as Exempt Organizations By Bradley T. Borden, Associate Professor of Law, Washburn University School of Law, Topeka, KS. This commentary is derived largely from Borden, Real Estate Transactions by Tax-Exempt Entities, 591 T.M./883 T.M. The use of limited liability companies and exempt organizations has exploded over recent years. The combination…

  • 529 Plans

    529 Plans Paying for Education as Part of an Estate Plan: 529 Plans By Elizabeth Carrott Minnigh, Esq., Buchanan Ingersoll & Rooney PC, Washington, DC One of the most important concerns for high net worth clients is how to best pay for the costs of higher education (i.e., college or graduate school) for children and…

  • Corporate Trustee Commissions

    Corporate Trustee Commissions Deductibility of Corporate Trustee Commissions By Sharon L. Klein, Esq. Senior Vice President, Trust Counsel and Director of Estate Administration, Fiduciary Trust Company International, New York, NY On January 16, 2008, the Supreme Court ruled that investment advisory fees incurred by individual trustees are deductible only under certain limited circumstances (Knight v.…

  • Internal Revenue Ruling 2004-2

    Internal Revenue Ruling 2004-2 — Health Savings Accounts (The reproduction of IRS information is provided only as a guide for the subject matter being discussed and is not intended as material to be absorbed for future testing.) Part III – Administrative, Procedural, and Miscellaneous Notice 2004-2 PURPOSE This notice provides guidance on Health Savings Accounts.…