Internal Revenue Service

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
News & Analysis as of

Reporting Foreign Account Gifts

One of the areas of inquiry that is certain to receive increased attention by the IRS and Department of Justice (DOJ) is the claim that the funds in offshore accounts were the result of a “gift”. The proper documentation of...more

More Post-Windsor Tax Guidance: IRS Issues Letter Outlining Steps for Individuals to Obtain Tax Refunds for Same-Sex Spousal...

On June 27, 2014, the IRS published a letter outlining the steps taxpayers should take in order to obtain a refund for taxes paid on the value of employer-sponsored health coverage provided to an employee’s same-sex spouse....more

PTC “Start of Construction” Clarifying Guidance Expected in a Week or Two

General Electric (GE) stated on its quarterly earnings call today that it expected that the clarification to the Internal Revenue Service’s (IRS) production tax credit (PTC) “start of construction” guidance would be released...more

IRS Gives QLACs the Green Light: Final Regulations Issued

On July 1, 2014, the Internal Revenue Service (“IRS”) issued final regulations (“Final Regulations”) that permit employers and IRA providers to offer “qualified longevity annuity contracts” or “QLACs” under defined...more

IRS Amends Regulations for Written Tax Advice: Say Goodbye to the Circular 230 Disclaimer at the End of Emails

Effective June 12, 2014, the IRS has announced revisions to Circular 230: Regulations Governing Practice Before the Internal Revenue Service that are designed, in part, to provide a more flexible standard for all written tax...more

New Streamlined Application Process for Tax Exempt Organizations Approved

On July 1, 2014, the Internal Revenue Service (IRS) radically changed the way nonprofits apply for exempt status by introducing the 1023-EZ form, an alternative process for applying for §501 (c) (3) tax- exempt status. As we...more

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

IRS’s Offshore Voluntary Disclosure Program: Current Streamlined Procedure

U.S. citizens and tax residents are required to report their world-wide income on their federal income tax returns. In addition, these U.S. persons are required, and have been required for some time, to separately report...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 24: Can Offers of Group Health Plan Coverage Under Code...

The Employer Shared Responsibility provisions of the Affordable Care Act (“ACA”) generally require “applicable large employers” (i.e., employers who employed at least 50 full-time and full-time equivalent employees on...more

Tax Litigation Update: Supreme Court Limits Taxpayers’ Ability to Fight IRS Summons

As we previously reported, on April 23, 2014, the United States Supreme Court heard oral argument in United States v. Clarke, a case which involved the extent to which a taxpayer may investigate the underlying reasons or...more

Limitation on IRA Rollovers: Once Per Year Only

The Internal Revenue Service (“IRS”) has narrowed the rules relating to Individual Retirement Account (“IRA”) rollovers by withdrawing longstanding proposed rules to reflect a recent U.S. Tax Court ruling in Bobrow v....more

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format...more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

IRS Introduces New Form 1023-EZ to Streamline Applications for 501(c)(3) Tax-Exempt Status

On July 1, 2014, the Internal Revenue Service (IRS) launched a new Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, that is intended to enable small...more

Quirky Question #234, Selling Accrued Vacation

Question: Our company allows employees to sell up to 40 hours of their accrued PTO (accrued vacation) each year. If an employee elects to sell the accrued PTO, we pay it out in a lump sum at the end of the year. Does...more

Failure to Report Cash Payment Over $10,000 May Lead to Government Penalties

For about 25 years, under federal law, businesses have had an obligation to properly handle and report cash payments exceeding $10,000. Some confusion still exists, however, concerning to what types of businesses the...more

Are You Eligible? IRS Releases Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the...

On July 1, 2014, the Internal Revenue Service ("IRS") released the much anticipated Form 1023-EZ, a shorter application that provides a quicker, more streamlined process for smaller organizations applying for recognition of...more

Affordable Care Act Update: Final Regulations Assist Employers With Identifying Full-Time Employees and Reporting Requirements

Earlier this year, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). We issued a Client...more

Internal Revenue Service Reveals 2013 Whistleblower Figures

“In this world nothing can be said to be certain, except death and taxes.” In the more than two centuries since Benjamin Franklin expressed those words, taxes have become perhaps even more of a certainty. The Internal Revenue...more

July and August 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

Recent Employee Benefits Developments

Amending Retirement Plans to Recognize Same-Sex Marriages Plan sponsors need to review retirement plan documents and operations to determine whether changes are needed in response to last year's Supreme Court decision in U.S....more

Employee Benefits: Important Wellness Plan and Mental Health/Substance Use Disorder Parity Effective Dates Have Arrived!

Employers and insurers offering medical plans: take note! Two important final regulations issued jointly by the IRS, DOL and HHS (the “Departments”) apply to plan years (or, in the individual market, policy years) beginning...more

The IRS’ New 2014 Offshore Voluntary Disclosure Procedures (Part 1)

Last weekend I published the introduction to my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. Below is Part 1 of his 6 part...more

Offshore Asset Reporting: Rules, Enforcement, and Options for Compliance

In this presentation: -Overview: Reporting Regimes for Offshore Assets -Department of the Treasury: Report of Foreign Bank and Financial Accounts (FBAR) -Form 8938, Statement of Specified Foreign...more

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