Impact of Final Check-th-Box Regulations Awaits Further IRS guidance and States' Input

Article Abstract:

The Internal Revenue Service published the Final Regulations revising rules for classifying business organizations for federal income tax purposes. This article examines these regulations and opportunities opened up for foreign entities as corporations, partnerships and LLCs.

Partnerships, Foreign corporations, Limited liability companies, Partnership, Classification

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Determining a 'Significant Modificationi' Under the Final Cottage Savings Regulations

Article Abstract:

This is an analysis of the tax consequences arising from a significant modification of debt instruments on borrowers and holders. Depending on the varying changes, the IRS may or may not consider it a taxable cancellation of debt.

Extinguishment of debts, Debt cancellation, Financial instruments, Debtor and creditor

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Proposed check-the-box business classificatin regulations simplify current rules

Article Abstract:

The new Internal Revenue Service "check-the-box" rules concerning business classification are discussed in detail. Existing tax provisions are expected to be simplified by the new rules.

Tax Law, Public Finance Activities, Corporate income taxes, Business enterprises, Income tax

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