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Obama Releases Fiscal 2017 Budget Proposal

Wednesday, February 10, 2016


The Administration released its proposed budget for fiscal 2017 ("Budget"), including many of the same tax proposals from previous budgets that have found no traction in Congress.

Second Quarter Priority Guidance Update

Tuesday, February 9, 2016


In the second quarter update ("Update") of its 2015-16 Priority Guidance Plan ("Plan"), IRS noted several projects it had completed, identified several new projects, and confirmed it had suspended the project to issue proposed regulations on electioneering by exempt organizations.

Palmer Ranch: 11th Circuit Reverses on Valuation Method

Tuesday, February 9, 2016

In Palmer Ranch Holdings Ltd. v. Commissioner, the 11th Circuit federal appeals court reversed in part a decision of the Tax Court, determining the lower court failed to value a conservation easement consistent with the comparable sales approach, and failed to observe other formalities.

PLR 201606005 - Late Election to Treat Controlled Entity as Taxable

Monday, February 8, 2016

In PLR 201606005, the Service allowed an entity controlled by an exempt organization to make a late election to be treated as a taxable entity for purposes of partnership passthroughs from a limited liability company.

PLR 201606033 - Set-Aside Approved

Monday, February 8, 2016

In PLR 201606033, the Service ruled an amount set aside by a private foundation to build a college campus in an economically depressed neighborhood would qualify as a distribution for purposes of the minimum payout requirement.

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