On May 12, 2023, IRS Office of Chief Counsel issued GLAM 2023-003 (the “GLAM”) analyzing the application of the “regularly traded stock exception” in Section 897(c)(3) to stock of a US real property holding corporation (“USRPHC”) held by partnerships. Though not...
The recent inaugural Tax Insurance Forum (TIF) hosted by tax advisory firm Leo Berwick in New York provided an opportunity for tax insurance brokers and underwriters to engage in a lively discussion led by several panelists. “The tax insurance market has grown...
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