News & Analysis as of

Cost-Sharing Internal Revenue Service U.S. Treasury

Husch Blackwell LLP

Federal Guidance On Balance Billing: The No Surprises Act And Its Interim Final Rule: Part I

Husch Blackwell LLP on

On July 1, 2021, the Office of Personnel Management (“OPM”), the Internal Revenue Service (“IRS”), the Department of Treasury (“Treasury”), the Employee Benefits Security Administration (“EBSA”), the Department of Labor...more

Morrison & Foerster LLP

Amazon Prevails in Ninth Circuit – Government Opportunism Rejected

Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute. The decision is also a victory for taxpayers generally because of the Ninth Circuit’s...more

Fisher Phillips

Staying Healthy: IRS Expands HDHP-HSA Preventive Care Benefits For Chronic Conditions

Fisher Phillips on

A Health Savings Account (HSA) is a popular vehicle for paying health care costs. Employees find HSAs attractive because they can control the amount of money contributed, determine when to withdraw money, and enjoy the...more

Mintz - Employment Viewpoints

Will Grandfathered Plans be Rescued?

On February 25, 2019 the Department of Labor, Department of Health and Human Services, Treasury Department and the Internal Revenue Service (the “Departments”) published a request for information (the “ROI”) on grandfathered...more

Eversheds Sutherland (US) LLP

Share and share alike - the Ninth Circuit upholds regulations on stock-based compensation costs in cost-sharing arrangements

On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. § 1.482-7A(d)(2), which provides that a...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - September 2015

Proskauer Rose LLP on

Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...more

McDermott Will & Emery

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

Morrison & Foerster LLP

No (Tax) Man Is Above the Law: The Tax Court Rejects Final Cost-Sharing Regulations in Altera Corporation and Subsidiaries v....

Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more

McDermott Will & Emery

Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

McDermott Will & Emery on

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

Proskauer - Employee Benefits & Executive...

Reminder: Non-Grandfathered Plans Must Implement Embedded Out-of-Pocket Maximums

As employers and plans prepare for 2016 open enrollment, they must be sure to address in their benefit design and with their third party vendors the new embedded out-of-pocket maximum limitations on individuals that were...more

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