The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “Temporary Regulations”) incorporating and expanding upon the ru...
On January 4, 2013, the Sixth Circuit denied the U.S. government’s petition for en banc review of its September 2012 decision in United States v. Quality Stores that certain severance p...
Today the House passed H.R. 4213, “American Jobs and Closing Tax Loopholes Act of 2010.” The bill contains both new proposals and proposals that were included in the Administration’...
On May 20, Democratic House and Senate tax writers released a tax extenders package (H.R. 4213) that includes provisions relating to the taxation of carried interest received by investmen...
This morning, the Obama Administration provided more detail on its previously announced plan to reform the U.S. tax laws relating to the taxation of income earned by foreign subsidiaries ...
The 2009 New York State budget proposed by Governor David Patterson yesterday contains a provision that would, effective January 1, 2009, impose New York tax on carried interest income al...
New rules on deferred compensation, enacted as part of the Emergency Economic Stabilization Act of 2008 on October 3, 2008, may have a much broader scope than originally anticipated. Thes...