JD Supra

A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a Partnership to That of an S Corporation

More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury ...
JD Supra

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such entities

On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain ...
The Tax Adviser

Frequently encountered controversy issues in M&A transactions

Procedural issues involving entity change in mergers and acquisitions can be managed by attentiveness and, in many cases, ...