I. INTRODUCTION Over the past 15 years, umbrella partnership structures (commonly referred to as “Up-Cs”), in which a newly-formed publicly traded C corporation (“PubCo”) acquires interests in an existing business operated in flow-through form...
Taxation Articles
Family Matters: 199A Common Ownership Definition Deemed Restrictive
Individual owners of a family business hoping to aggregate their ownership interests for purposes of the section 199A deduction may run into trouble if the co-owners happen to be siblings. The proposed passthrough regulations allow taxpayers to...
Employer’s Guide to Navigating ACA Reporting Requirements
Beginning in 2015, certain employers were required to report information to the IRS on an annual basis to assist the IRS in assessing penalties associated with the employer shared responsibility and individual mandate requirements of the Affordable...
PCAOB Chairman Duhnke Says Audit Inspections to Change in 2019
PCAOB Chairman William Duhnke said the board plans to change the way it inspects accounting firms beginning with the 2019 inspection cycle. The upcoming change is a result of the PCAOB's review of its inspections program and follows a wholesale...
SEC and PCAOB officials join attorneys in discussion on defense strategies
The American Law Institute CLE’s recent Accountants’ Liability Conference featured a panel discussion on substantive defense strategies in SEC and PCAOB proceedings starring representatives from both sides of the table. The panelists went over a...
PCAOB Senior Positions to Be Filled by Year-end, Chairman Duhnke Says
PCAOB Chairman William Duhnke expects to fill the vacant posts at the head of the regulatory board's various offices before the end of the year. "I can't give you a specific date. But our goal is by the end of the year to have all our senior...
Executive Compensation Excise Tax Guidance
Some questions about the new excise tax on nonprofit executive compensation — like how to treat employees from a company’s “predecessor” — might not make it into initial guidance. The predecessor question might not be a “first-round issue” given...
Outline of the Federal Gift Tax
In the following Federal Gift Tax Outline: Transactions subject to Gift Tax Annual Exclusions (IRC Section 2518) Gift splitting (IRC Section 2513) Disclaimers (IRC Section 2518) Marital Deduction (IRC Section 2523) Charitable Deduction [line] I....
FMLA Credit’s Availability Depends on Local and State Laws
A new federal [FMLA] credit for paid employee leave isn’t available to employers whose states or localities mandate the benefit. Carol Weiser, acting benefits tax counsel at the Treasury Department, made that point September 25 while discussing...