Tax

The Internal Revenue Service (the “Service”) is considering requiring businesses to report “uncertain tax positions”  if they are “a business taxpayer with total assets in excess of $10 million…. [or] a taxpayer who prepares financial statements, or is included in the financial statements of...

I first wrote about proposed changes in the taxation of carried interests (the manager's share of income from a venture or private equity fund) in June of 2008 (see http://archive.constantcontact.com/fs056/1101631528224/archive/1102150842963.html). Last December, the House finally approved a bill to tax carried interests at ordinary...

The Obama administration has just made my year-end busier. On November 7th, the President signed into law the Worker, Homeowner, and Business Act of 2009 (the “WHB 2009 Act”) which, among other things, extends the period that businesses can carry back a net operating...

By now, everyone has heard of Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”), which has turned traditional deferred compensation on its head by including deferrals in gross income unless they meet strict requirements.  While Hollywood may have been the...

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