July 24, 2017
Tax Court Rejects Controversial IRS Position in Rev. Rul. 91-32
The Tax Court in Grecian Magnesite Mining, Co. v. Commissioner rejected the controversial IRS position in Rev. Rul. 91-32 that a foreign partner’s capital gain from the sale of an interest ...
March 09, 2018
Federal Tax Reform: Amended Sec. 163(j) Interest Expense Limitation and State Tax Conformity Issues
Recent federal tax reform legislation amended Internal Revenue Code (the Code) Sec. 163(j), effective for tax years beginning after 2017. Amended Sec. 163(j) generally limits a business’s annual interest expense deduction to 30% ...
August 14, 2018
Hogan Quoted in Tax Notes Article Regarding Proposed IRS Regulations
Andersen Managing Director Jim Hogan was quoted in IRS Puzzles Over 199A Application to Charitable Remainder Trusts, a Tax Notes article written by Jonathan Curry. The article includes discussion and opinions from various ...
August 22, 2018
Hogan Quoted in Bloomberg BNA Tax Article
Andersen Managing Director Jim Hogan was quoted in a Bloomberg BNA tax article titled Use Trusts for Pass-Through Tax Break? Yes, You Still Can. The article includes discussion on whether taxpayers should ...
October 19, 2018
Treasury Releases Proposed Regulations on Qualified Opportunity Zones
Treasury and IRS have released the first set of proposed regulations on the new Qualified Opportunity Zone (QOZ) tax incentives created by the Tax Cuts and Jobs Act (TCJA). The proposed regulations clarify ...
November 16, 2018
Germanese Presenting at the New England IRS Representation Conference
The New England IRS Representation Conference brings together government representatives and private practitioners to compare perspectives on a variety of topics involving federal tax audits, appeals, and litigation. The annual conference covers ...
November 28, 2018
IRS Issues Proposed Regulations on New Interest Deduction Limitation
IRS has issued proposed regulations on the new business interest limitation under Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA). The proposed regulations broadly define interest for purposes of ...
November 29, 2018
Hogan Quoted in Tax Notes Article Regarding Estate Planning
Andersen Managing Director Jim Hogan was quoted in a recent Tax Notes article written by Jonathan Curry. The article titled, Estate Planners Proceeding with Caution Absent Clawback Guidance, provides insight ...
January 25, 2019
Final Regulations on 20% Pass-Through Deduction Resolve Various Uncertainties
IRS and Treasury have released final regulations under Sec. 199A of the Internal Revenue Code (Code) regarding the 20% deduction for pass-through entities and certain individuals. The final regulations clarify important definitions, discuss computational ...
March 13, 2019
Hogan to Speak at California Lawyers Association 27th Annual Estate and Gift Tax Conference
The California Lawyers Association (CLA) is hosting their 27th Annual Estate and Gift Tax Conference on March 14-15, 2019 at the University of San Francisco School of Law. Managing Director James Hogan, ...