U.S. Treasury Department Issues Second Report On Identifying And Reducing Tax Regulatory Burdens: Repeal Of Section 2704 Regulations And Revisions Pending To The Regulations Issued On Partnership Debt
As recently set forth in a post to K&F, LLP Business and International Tax Developments, in Executive Order 13789, President Trump directed the Treasury Department to undertake a detailed review of certain tax regulations projects that were either in proposed or final form on or after January 1, 2016 that imposed financial burdens on U.S. taxpayers, overly complicate the Federal tax laws, or exceed the statutory authority of the IRS in issuing regulations and report back to the President on its recommendations.
Action Expected Shortly By U.S. Treasury On Outbound Transfers As Well As Other Important Issues, Including The Branch Currency Rules
Shortly after President Trump took the oath of office as President, on April 21, 2017, President Trump issued Executive Order 13789, a directive intended to reduce tax regulatory burdens on the IRS and Treasury. The order instructed the Secretary of the Treasury to review all “significant tax regulations” issued on or after January 1, 2016 by the predecessor administration, and submit two reports, followed promptly by taking concrete action to alleviate the burdens of regulations that meet criteria outlined in the order.
Jerald David August Presented The ALI Webcast "The New Partnership Audit Rules: How Will They Impact Privately-Owned Businesses And Family Partnerships?"
This webcast included an inside look at the new centralized partnership audit regime and the challenges the IRS is addressing in the final regulations. Attendees heard a key IRS drafter of the proposed regulations in a give-and-take discussion with experienced counsel as he explained how the regulations are intended to work and explored the problem areas still under review. The panelists also examined issues in drafting and revising partnership agreements in response to the new rules.
Jerald David August presented "ASC 740-10 (FIN 48) and Uncertain Tax Positions; IRS’ Ability to Summons Tax Accrual Workpapers" at the Long Island Tax Executives Institute
Mr. August shared his extensive knowledge on the subjects with those in attendance.
Buy Sell Agreements In Canada And Their Impact On Preserving The Tax Favored Status Of Canadian Resident Controlled Private Corporations
Canadian Controlled Private Corporations
In a recent article written by lawyers in the Aird & Berlis LLP law firm in Toronto, which was just published in Tax Notes International, U.S. international tax practitioners and business lawyers can obtain valuable insights on drafting issues and problems with Canadian controlled private corporation (CCPC) shareholder agreements. The idea is to preserve favorable tax attributes of a Canadian private corporation by ensuring that de jure and de facto control of the CCPC is maintained by Canadian persons throughout.
Former Credit Suisse Banker Pleads Guilty To Conspiring With U.S. Taxpayers And Other Swiss Bankers To Defraud The United States
Department of Justice Press Release of July 19, 2017.
In its press release of July 19, the Department of Justice announced that a citizen and resident of Switzerland pleaded guilty to conspiring to defraud the United States in connection with her work as the head of a team of bankers for Credit Suisse AG, announced Acting Deputy Assistant Attorney General Stuart M. Goldberg of the Justice Department’s Tax Division and U.S. Attorney Dana J. Boente for the Eastern District of Virginia. Ms. Meier was indicted in 2011 that was part of a number of cases filed by the United States on offshore tax evasion.
Drafting Partnership Agreement Provisions With Respect To Partnership Audits Both Under TEFRA And The New Bipartisan Budget Act Of 2015
Focusing On The Controversial New Partnership Representative Rule
Partner, Kostelanetz & Fink, LLP 
This is the second part of a series of posts pertaining to drafting and revising partnership, limited liability and limited liability partnership (“partnership”) agreements into account the new consolidated audit rules. The first part of the series appeared on this website, “Business and International Tax Developments” on Friday, June 14, 2014. .
The new partnership audit rules are quite important not only for tax lawyers but for business lawyers and estate planners who undertake to advise clients on partnership agreements and further undertake the responsibility for negotiating and drafting such agreements. Let’s not forget to mention that the clients must have a general understanding of the new rules.