Kristen E. Hazel
By Kristen E. Hazel, Michael J. Wilder and Michael F. Kelleher on Dec 7, 2017
Posted In Tax Reform, Uncategorized
A number of provisions included in the Senate’s tax reform bill, H.R. 1 (the Senate Bill) would impact the insurance sector. Many of the provisions would affect only the life insurance industry. Others affect property & casualty (P&C) insurance companies. Still others affect both life and P&C insurance companies. Many of these proposals align with proposals...
By McDermott Will & Emery, Alejandro Ruiz, David G. Noren, Jean A. Pawlow, Kevin Spencer, Kristen E. Hazel, Robin L. Greenhouse, Sandra P. McGill and Timothy S. Shuman on Nov 1, 2017
Posted In Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized
The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues. Republican Leaders Release Tax Reform Framework By David G. Noren Alexander Lee M&A Tax Aspects...
Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest
By Kristen E. Hazel and Sandra P. McGill on Aug 16, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Tax Refunds, Trial Courts, Uncategorized
In a long-awaited decision, the US Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to follow Revenue Ruling 91-32. The government has yet to comment regarding...
By Kevin Spencer, Kristen E. Hazel and Madeline Chiampou Tully on Dec 27, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
On November 2, 2015, the Bipartisan Budget Act of 2015, (the Act), H.R. 1314, 114 Congress/Public Law No. 114-74, made significant changes to the rules governing US federal income tax audits of partnerships (New Audit Rules). The New Audit Rules are codified at Internal Revenue Code Sections 6221 through 6241. On August 4, 2016, the...
By Kristen E. Hazel and McDermott Will & Emery on Nov 11, 2016
Posted In IRS Guidance, Uncategorized
In Notice 2016-66, the Treasury Department and the Internal Revenue Service (IRS) identified a particular § 831(b) “micro-captive” transaction as a “transaction of interest” for purposes of § 1.6011-4(b)(6) of the Regulations and §§ 6111 and 6112 of the Internal Revenue Code. The notice also alerts persons involved in such transactions to certain responsibilities and...
By Jennifer M. Mikulina and Kristen E. Hazel on Nov 4, 2016
Posted In IRS Appeals, IRS Audits, Uncategorized
On November 3, 2016, we presented at the Chicago Tax Club’s symposium regarding tax planning and intellectual property (IP) planning within a multinational corporation. The presentation covered various areas, including the importance of coordination between IP and tax groups when engaging in IP planning, the differences in the IP arena and the tax arena with respect...
By Kristen E. Hazel and McDermott Will & Emery on Feb 24, 2016
Posted In Appellate Courts, IRS Guidance, Uncategorized
In mid-2015, the United States Court of Appeals for the District of Columbia Circuit affirmed (although on narrower grounds) the decision of the United States District Court for the District of Columbia in Validus Reinsurance, Ltd. v. United States. In Validus, 786 F.3d 1039, the D.C. Circuit ruled that there was no statutory authority for...