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Thompson & Knight LLP
Dallas, Texas
T&K Tax Knowledge
Recent Activity
T&K Diversity Spotlight: Women’s History Month/Emily Parker
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Honoring Emily Parker In honor of Women’s History Month, we are proud to highlight the accomplishments of Emily A. Parker, the Firm’s first female attorney and Partner. Over the course of her career, Emily has excelled in industries and practice areas not traditionally associated with women, breaking through the glass... Continue reading
Posted Mar 14, 2019 at T&K Tax Knowledge
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Proposed Regulations Liberalize Requirements for Hardship Distributions
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Posted by Russell Gully, Sharon Fountain, and Jessica Morrison Most 401(k) and 403(b) plans allow plan participants to take in-service hardship distributions. In response to various pieces of tax legislation, the Department of the Treasury and the Internal Revenue Service proposed new Treasury Regulations governing hardship distributions effective generally for... Continue reading
Posted Dec 13, 2018 at T&K Tax Knowledge
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2019 Cost-of-Living Adjustments Applicable to Employee Benefit Plans
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Posted by Neely Munnerlyn The Internal Revenue Service has announced the cost-of-living adjustments for limitations applicable to employee benefit plans qualified under the Internal Revenue Code. See our client alert for more information. If you have any questions, please contact the T&K tax attorney with whom you regularly work or... Continue reading
Posted Dec 12, 2018 at T&K Tax Knowledge
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Bypass Trust Planning in a High Exemption Environment
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Posted by Bill Mureiko and Sarah Woodberry After President Trump signed the Tax Cuts and Jobs Act tax reform bill (the “Tax Bill”) into law at the end of 2017, many clients may have been lulled into thinking that no update to their existing estate plan is required, given the... Continue reading
Posted Oct 9, 2018 at T&K Tax Knowledge
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President of Mexico Passes Decree Including Tax Amendments
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Posted by Mario Barrera On June 1, 2018, Mexican President Enrique Peña Nieto published a decree in the Federal Register amending several provisions of different statutes, including the Federal Fiscal Code (Código Fiscal de la Federación). The most relevant amendments to the Code are the following: 1. For persons engaged... Continue reading
Posted Jun 7, 2018 at T&K Tax Knowledge
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Lee Meyercord Quoted on New Partnership Audit Rules
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Posted by Lee Meyercord and Mary McNulty Lee Meyercord was on several panels last week regarding the new partnership audit rules at the Federal Tax Workshop in Dallas. The panels discussed calculating and modifying the imputed underpayment, the push-out election (including the proposed regulations issued last December that allow the... Continue reading
Posted Mar 30, 2018 at T&K Tax Knowledge
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IRS Extends Effective Period of 2017 Forms W-4
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Posted by Neely Munnerlyn In Notice 2018-14, the IRS extended the effective period of Forms W-4, Employee’s Withholding Allowance Certificate, for 2017 until February 28, 2018. A Form W-4 that claims an exemption from withholding for a year typically expires on February 15 of the following year, but this period... Continue reading
Posted Feb 13, 2018 at T&K Tax Knowledge
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IRS Updates Withholding Tables for 2018
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Posted by Neely Munnerlyn The Internal Revenue Service recently released Notice 1036, which updates the income tax withholding tables for 2018 to reflect changes made by the tax reform legislation enacted last month. The updated tables reflect the increased standard deduction, repeal of personal exemptions and adjusted tax rates included... Continue reading
Posted Jan 23, 2018 at T&K Tax Knowledge
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New Tax Law Includes Significant Changes Affecting Tax-Exempt Organizations
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Posted by David Rosenberg, Tyree Collier, Lee Meyercord, Katie Gerber, and Jackson Oliver The new tax bill enacted in December (the “Tax Bill”) includes many changes affecting tax-exempt organizations, including changes to excise taxes imposed on private foundations and universities, the charitable donations deduction, tax-exempt bonds, and the treatment of... Continue reading
Posted Jan 18, 2018 at T&K Tax Knowledge
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Foreign Financial Institutions Receive Some Relief from FATCA TIN Reporting Requirement
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Posted by Joe Rudberg, John Cohn, and Jana Benson On September 25, 2017, the IRS released Notice 2017-46 providing much anticipated official relief to foreign financial institutions (FFIs) facing requirements to obtain and report taxpayer identification numbers (TINs). Earlier this year, regulations were released under the Foreign Account Tax Compliance... Continue reading
Posted Dec 11, 2017 at T&K Tax Knowledge
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2018 Cost-of-Living Adjustments for Employee Benefit Plans
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Posted by Sharon Fountain, Russell Gully, Jason Loden, Jessica Morrison, Neely Munnerlyn, and Shelly Youree The Internal Revenue Service recently announced the 2018 calendar year cost-of-living adjustments for limitations applicable to employee benefit plans qualified under the Internal Revenue Code. Thompson & Knight's employee benefits group has produced a client... Continue reading
Posted Nov 6, 2017 at T&K Tax Knowledge
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Lee Meyercord Quoted on New Partnership Audit Rules
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Posted by Lee Meyercord and Mary McNulty Lee Meyercord was recently quoted in a Tax Notes Today article (subscription required) and a Bloomberg Law article (subscription required) on her testimony at the IRS hearing on the proposed partnership audit regulations. Meyercord testified at the IRS hearing on behalf of the... Continue reading
Posted Oct 5, 2017 at T&K Tax Knowledge
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Tax Court Holds Microcaptive's Policies Not Insurance
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Posted by Todd Keator and Murtuza Hussain In a recent case, Benjamin Avrahami v. Commissioner, 149 T.C. No. 7 (August 21, 2017), the Tax Court held that payments, including those to a microcaptive, were not for insurance and therefore were not deductible under Section 162. Furthermore, since less than half... Continue reading
Posted Oct 2, 2017 at T&K Tax Knowledge
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Section 1031 Drop & Swap Transactions
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Posted by Todd Keator Todd Keator recently gave a presentation addressing Section 1031 exchange “drop & swap” (and “swap & drop”) transactions. A “drop & swap” colloquially refers to a 1031 exchange involving a partnership where the partners either complete individual 1031 exchanges at the partner level or some of... Continue reading
Posted Sep 7, 2017 at T&K Tax Knowledge
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New Partnership Audit Rules
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Posted by Lee Meyercord and Mary McNulty Lee Meyercord recently gave a presentation at the 2017 State Bar of Texas Advanced Tax Law Course on the new partnership audit rules. The presentation discussed in detail the rules in the proposed regulations, which filled many of the gaps in the statutes... Continue reading
Posted Sep 6, 2017 at T&K Tax Knowledge
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Tax Court Holds Foreign Partner’s Gain on U.S. Partnership Interest Redemption is Not Subject to U.S. Taxation
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Posted by John Cohn, Todd Keator, and Kathleen Gerber In a recent case, Grecian Magnesite Mining, Industrial & Shipping Co., S.A., v. Commissioner, 149 T.C. No. 3 (July 13, 2017), the Tax Court declined to apply the principles of Rev. Rul. 91-32 when determining whether gain realized by a foreign... Continue reading
Posted Jul 31, 2017 at T&K Tax Knowledge
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IRS Reissues Much-Anticipated Proposed Regulations on Partnership Audit Rules
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord The IRS reissued the proposed regulations on the new partnership audit rules that were released in January but subsequently withdrawn in response to the Trump Administration’s freeze on new regulations. As noted by Mary A. McNulty in a Tax Notes Today... Continue reading
Posted Jun 14, 2017 at T&K Tax Knowledge
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New Alternative Substantiation Guidelines for Hardship Withdrawals
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Posted by Sharon Fountain, Russell Gully, Jason Loden, Jessica Morrison, Neely Munnerlyn, and Shelly Youree The IRS recently described new alternative substantiation guidelines for its Employee Plans Examination employees to follow when they audit hardship withdrawals from a 401(k) plan or 403(b) plan. Thompson & Knight's employee benefits group has... Continue reading
Posted Jun 6, 2017 at T&K Tax Knowledge
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QSEHRA, Sera: Small Employers Catch a Break from ACA Rules
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Posted by Russell Gully and Jessica Morrison Overshadowed by the political drama surrounding the Affordable Care Act (ACA) is tax legislation enacted in December 2016 to make stand-alone health reimbursement arrangements (HRAs) available to employees of certain small employers. An HRA typically consists of an arrangement under which an employer... Continue reading
Posted Apr 3, 2017 at T&K Tax Knowledge
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IRS Releases Unofficial Proposed Regulations on Partnership Audit Rules
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord On January 18, 2017, the IRS released unofficial proposed regulations on the new partnership audit rules in the Bipartisan Budget Act of 2015 (“BBA”). The rules are “unofficial” because they have not yet been published in the Federal Register. As observed... Continue reading
Posted Mar 2, 2017 at T&K Tax Knowledge
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Todd Keator Cited in Preamble to Final Regulations on PTP Qualifying Income
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Posted by Todd Keator On January 19, 2017, the IRS issued final regulations under Section 7704(d)(1)(E) regarding the scope of the qualifying income exception for publicly traded partnerships (“PTP”) engaged in activities with respect to minerals or natural resources. The regulations are available here. PTPs are treated as corporations for... Continue reading
Posted Feb 13, 2017 at T&K Tax Knowledge
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Mary McNulty Quoted on Proposed Technical Corrections to Partnership Audit Rules
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord Mary A. McNulty was recently quoted in a Tax Notes Today article (subscription required) on the proposed Tax Technical Corrections Act of 2016 (available here), which makes technical corrections to the new partnership audit rules in the Bipartisan Budget Act of... Continue reading
Posted Jan 4, 2017 at T&K Tax Knowledge
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Proposed Tax Technical Corrections Act of 2016 Addresses Open Issues in Partnership Audit Rules
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord The Tax Technical Corrections Act of 2016 (available here) introduced recently makes technical corrections to the new partnership audit rules in the Bipartisan Budget Act of 2015 (“BBA”). The BBA repealed and replaced the 1982 Tax Equity and Fiscal Responsibility Act... Continue reading
Posted Dec 19, 2016 at T&K Tax Knowledge
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IRS Finalizes Regulations Regarding Reporting of U.S. Disregarded Entities Owned by Foreign Persons
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Posted by John Cohn In May, the IRS proposed regulations to require reporting foreign-owned domestic disregarded entities, ownership and the transactions in which they enter with related parties. See here. Yesterday, the IRS finalized these regulations (available here) making a few minor changes. Under current law, a wholly-owned domestic limited... Continue reading
Posted Dec 13, 2016 at T&K Tax Knowledge
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2017 Cost-of-Living Adjustments for Employee Benefit Plans
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Posted by Sharon Fountain, Russell Gully, Jason Loden, Jessica Morrison, Neely Munnerlyn, and Shelly Youree The Internal Revenue Service recently announced the 2017 calendar year cost-of-living adjustments for limitations applicable to employee benefit plans qualified under the Internal Revenue Code. Thompson & Knight's employee benefits group has produced a client... Continue reading
Posted Nov 8, 2016 at T&K Tax Knowledge
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