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Jeff A. Kieckhafer
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Gregory A. Fletcher
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Treasury Provides Welcome Grace Period and Transition Relief from Repeal of the “338 Approach” to Recognition of Built-in Gains (but the clock is ticking)
On January 14, 2020, the IRS and Treasury provided partial relief from their earlier announcement of the repeal of a highly favorable method of increasing…
Read MoreTreasury Releases Final Section 385 Regulations without Substantive Changes to the 2016 Proposed Regulations.
Internal Revenue Code (IRC) Section (§) 385(a) provides that the Secretary of the Treasury is authorized to prescribe regulations as may be necessary or appropriate…
Read MoreCompanies Continue to Evaluate APB 23 Benefits After Tax Reform; Impact of COVID-19 Related Repatriations on the Indefinite Reinvestment Assertion
The general comprehensive rule for providing deferred taxes on book-tax basis differences under ASC 740-10 requires companies to record a deferred tax liability (DTL) for…
Read MoreProposed Regulations Deny the Deductibility of Certain Fines, Penalties, and Other Amounts Under Section 162(f), and Impose Reporting Requirements
The IRS and Treasury released proposed regulations that offer guidance concerning the recent expansion of the limitations on deducting certain fines, penalties, and other amounts…
Read MoreWashington, Clackamas, and Multnomah Counties Pass 1% Tax on High-Wealth Individuals and Large Businesses to Fund Housing to Reduce Homelessness
On May 19, 2020, voters in Washington, Clackamas, and Multnomah counties approved Measure 26-210, which funds services, including health care, case management, job training, and…
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