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

Extremely Low Interest Rates: Your Estate Planning Opportunity is NOW

Janet Yellen this…. Janet Yellen that – good for business, bad for savers. In March 2015, the rates the IRS requires be used for estate planning are as low as ever. There are three estate planning opportunities that thrive on...more

IRS Clarification on Non-Willful Conduct Certification for Streamlined Offshore Compliance Procedures: Revisions to IRS Forms...

Many U.S taxpayers are often surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their obligation, there are a number of programs through...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

IRS Issues Preliminary Guidance on Cadillac Tax

Monday, the Internal Revenue Service issued preliminary but much-anticipated guidance on the so-called Cadillac tax imposed by the Affordable Care Act (ACA). The new notice offers very few concrete answers to employer...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

IRS Issues Final Forms for Affordable Care Act Reporting

The Internal Revenue Service has finalized the forms and instructions for reporting information necessary for enforcement of the individual and employer mandates under sections 6055 and 6056 of the Internal Revenue Code. The...more

IRS Announces That It Will No Longer Refund FICA Taxes on Severance Payments

The IRS recently announced that severance payments are taxable wages under FICA, and thus employers who seek tax refunds on those payments will be denied. The IRS’s position reflects the United States Supreme Court’s ruling...more

Limited Transition Relief Provided for Employer Payment Plans

The Internal Revenue Service (IRS) recently issued additional guidance (Notice 2015-17) addressing the treatment of arrangements whereby an employer reimburses an employee for some or all of the premium expenses incurred for...more

Partial Relief for Employer Payment of Individual Insurance Premiums

In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more

Reimbursing Employees for Health Premiums Could Trigger ACA Penalties

Q. "I’m a small business owner with fewer than 50 employees. I do not offer health insurance coverage for my employees, but I do reimburse them for their substantiated health insurance premium payments. I normally deduct the...more

Temporary Waiver of ACA Penalties for Small Employers’ Individual Insurance Premium Reimbursement Plans

Last week, the IRS announced the waiver (for 2014 and the first half of 2015) of the penalty for “small” employers that reimburse employees for individual health insurance premiums. To the IRS, “small employer” means an...more

Accountant and Attorney Liability Newsbrief - Winter 2015

In This Issue: - The Affordable Care Act and CPAs: It Takes a Village - U.S. District Court for District of Massachusetts Holds Testator’s Attorney Can Be Held Liable to A Beneficiary - New Jersey...more

Health Care Update - February 2015 #3

In This Issue: - IRS in the ACA Spotlight - DOJ and FTC Examine Competition - Implementation of the Affordable Care Act - Other Federal Regulatory Initiatives - Congressional Initiatives - Other...more

New IRS guidance for certain entities benefitting from tax-exempt bond financings

The IRS has released guidance in three areas of interest to entities that benefit from tax-exempt bond financings, particularly hospitals and educational institutions....more

Hollow Taxpayer Victory When IRS Unlawfully Discloses Taxpayer Information to Japan

By law, the U.S. is not permitted to disclose false return information, even if the release of false return information is authorized by law and treaty. Code Section 7431 imposes liability on the U.S. if it discloses return...more

IRS Clarifies Prior Guidance on Premium Reimbursement Arrangements; Provides Limited Relief

Continuing its focus on so-called “premium reimbursement” or “employer payment plans”, the Internal Revenue Service (IRS) released IRS Notice 2015-17 on February 18, 2015. In this Notice, which was previewed and approved by...more

Client Alert: IRS Announcement on February 9, 2015, Requires Review of Charter Schools Tax Status

On November 8, 2011, the IRS and Treasury Department published an Advance Notice of Proposed Rulemaking (“2011 Advance Notice”) that posed a threat to charter school participation in public pension plan systems. The 2011...more

New York Restaurateur Pleads Guilty to Hiding Money in Swiss Accounts

On February 19, 2015, Georges Briguet, the owner of New York restaurant Le Perigord, pleaded guilty to one count of corruptly endeavoring to obstruct the IRS by concealing the existence of his Swiss bank accounts. According...more

Medical Insurance Premium Reimbursement — A Brief Reprieve for Small Employers

Some employers – particularly smaller ones – have assisted their employees to obtain health insurance by reimbursing them for the cost of insurance they purchase in the individual market. Does this practice satisfy the...more

Supplemental Excepted Benefits? “It depends.”

Last week, HHS, along with the Department of Labor and the Treasury, provided long overdue guidance regarding the third category of supplemental “excepted benefits” as defined by Section 2791 of the Public Health Services...more

Tax Alert: Three Critical Letters from the IRS - Why not to ignore them, what they mean and how to respond

All correspondence from the Internal Revenue Service should be taken seriously; however, some letters and notices have more legal consequences than others....more

Application For Recognition As A 501(C)(29) Organization

The Internal Revenue Service (IRS) and Department of the Treasury (Treasury) published in the January 29, 2015 Federal Register final income tax regulations (Regulations) describing procedures by which a qualified nonprofit...more

IRS Issues Regulations on Section 501(r) Applicable to Charitable Hospitals

On December 29, 2014, the IRS issued final regulations under Section 501(r) of the Internal Revenue Code. Section 501(r) requires charitable hospitals to meet the following requirements in order to be tax-exempt...more

The Digital Economy: The Tax Man is Coming

Once again, we find ourselves faced with a proposal attempting to target and provide special tax rules for income generated in the digital economy. As was the case in the previous year’s budget proposal, the Administration’s...more

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