Entity Classification Internal Revenue Code

New Partnership Audit Rules

The Bipartisan Budget Act (“Act”) was signed into law on November 2, 2015 amending the rules concerning how entities taxed as partnerships will be audited by the IRS and who…

Elections Forms and Filings Internal Revenue Code Nonresidents

Benefits of Election 83(b) for Nonresidents

An individual who receives property in exchange for the performance of services generally would report the fair market value of that property received as ordinary income, subjecting the individual imposition…

Compliance Issues Internal Revenue Code Switzerland Tax Compliance

Justice Department Expecting to Collect over $1.36 billion from Swiss Banks

In the beginning of 2016, the Justice Department reported that it is expecting to collect over $1.36 billion from 80 Swiss banks and financial institutions that admitted to aiding U.S….

Entity Classification Internal Revenue Code Internal Revenue Service

Changes to the § 108 Exclusion Rule

Normally, under Internal Revenue Code § 61(a)(12), income from the discharge of indebtedness is includable in gross income, however, such income may be excludable from gross income under certain exceptions…