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Death Tax Compromise Talks in Senate

At the Finance Committee markup last week on the Agriculture bill, Senator Jon Kyl (R-AZ) offered an amendment to make permanent changes to the estate tax.

The Kyl amendment would have created a new framework for future estate tax levies with a $5 million unified exemption (per spouse) and a two-tiered rate system: capital gains rates for estates up to $25 million and 30 percent rates for estates above $25 million.

In exchange for Senator Kyl withdrawing his amendment, Finance Committee Chairman Senator Max Baucus (D-MT) promised to hold hearings on the estate tax later this year followed by a markup of

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2019-02-06T18:44:37+00:00October 11, 2007|

IRS Announces Simplified Process for Late S Corporation Elections

The IRS yesterday announced a new procedure designed to simplify the process for taxpayers wanting to request relief for late S corporation elections. According to the new procedure, companies will now be able to file their S corporation election form at the same time they file their taxes as an S corporation, provided they have a good reason for the late submission.

This is the latest of several simplifications the IRS and Treasury Departments have announced for the S corporation community in recent months.

The full text of the announcement can be found

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2019-02-06T18:44:37+00:00October 10, 2007|

IRS Issues Guidance on S Corporation Rules and Definitions

Yesterday, the IRS released a set of proposed regulations to clarify S corporation family shareholder rules as well as definitions of “powers of appointment” and “potential current beneficiaries” of ESBTs. Changes were also made to Treasury regulations in accordance with the Small Business Job Protection Act of 1996.

The IRS is encouraging public comments on these changes, which must be submitted to the IRS for review by Dec. 27, 2007. A hearing to discuss the proposed regulations is currently scheduled for Jan. 16, 2008 at 10:00am. Comments,

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2019-02-06T18:44:37+00:00September 28, 2007|

AMT and Corporate Tax Rates Together? Watch Out

As we have previously reported, Chairman Charlie Rangel has a deep interest in passing a permanent “fix” to the Alternative Minimum Tax. Meanwhile, Treasury Secretary Paulson has kicked-off efforts to cut the corporate tax rate in order to make our corporations more competitive on the world stage.

Now the word on the Hill is that these two unrelated agendas may collide in the next week or two at a Ways and Means Committee hearing, and possibly at the end of the year as a massive tax reform package.

As BNA reported last week (subscription required), Chairman

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2019-02-06T18:44:37+00:00September 25, 2007|

Congress Returns

Congress came back from its August break this week and is picking up right where it left off, struggling with the question of what to do with the Alternative Minimum Tax and examining how to appropriately tax the carried interest earned by hedge fund managers and other general partners.

These questions are connected, obviously, in that addressing the AMT will be very expensive while raising the tax rates on carried interest would presumably raise lots of revenue. That’s one reason why both the Ways and Means and

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2019-02-06T18:44:37+00:00September 7, 2007|