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McDermott Will & Emery

Weekly IRS Roundup June 17 – June 21, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup May 27 – May 31, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27, 2024 – May 31, 2024. ...more

Verrill

Section 457(f) Plans and Noncompete Clauses: What the IRS Gave, the FTC May Take Away

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When the IRS published proposed regulations harmonizing key provisions of Code Sections 409A and 457(f) in 2016, executive compensation lawyers and consultants rejoiced. It was not just that a long wait was over (roughly nine...more

McDermott Will & Emery

Weekly IRS Roundup April 15 – April 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15, 2024 – April 19, 2024. ...more

Sherman & Howard L.L.C.

FinCEN Implies Certain Tax-Exempt Entities Are Subject to the CTA (They’re Not)

As companies across the nation grapple with the reality of complying with the Corporate Transparency Act (CTA), which went into effect on January 1 of this year, certain nonprofits that expected to be exempt from such toils...more

McDermott Will & Emery

Weekly IRS Roundup January 8 – January 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 8, 2024 – January 12, 2024....more

Verrill

DOL Proposes Amendments to QPAM Exemption

Verrill on

On July 27, 2022, the Department of Labor (DOL) proposed a set of amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” which permits an investment fund holding assets of ERISA plans and...more

Nilan Johnson Lewis PA

Dear Nonprofits – The IRS is Making Use of an LLC Easier

Nilan Johnson Lewis PA on

For nonprofits and the lawyers who love them, 2020 and 2021 have been full of frustrating interactions with the IRS. Getting the IRS to acknowledge and respond to basic communications has seemed more difficult than in the...more

BCLP

EO Update: e-News for Charities & Nonprofits - June 2021

BCLP on

Update on Mandatory Electronic Filing for Form 4720 by Private Foundations - Section 3101 of the Taxpayer First Act requires certain exempt organizations to file information and tax returns electronically for tax years...more

Mintz

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

Mintz on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

Foley & Lardner LLP

U.S. Tax Court Ruling Exempts Gain on Foreign Partner's Sale of a Partnership Interest

Foley & Lardner LLP on

On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more

Miles & Stockbridge P.C.

Supreme Court Clarifies Limits to ERISA Church Plan Exemption

On March 27, 2017, the then 8 Supreme Court Justices heard oral arguments for three consolidated cases regarding the outer bounds of the “church plan” exception under the Employee Retirement Income Security Act of 1974...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Gerald Nowotny - Law Office of Gerald R....

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

Goodwin

Financial Services Weekly News - September 2016 #3

Goodwin on

Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

McDermott Will & Emery

Review of Section 409A Proposed Regulations

On June 22, 2016, the Internal Revenue Service (IRS) issued proposed changes to the regulations under the Internal Revenue Code (Code) §409A. The Code intends to clarify or modify a wide range of very restrictive rules...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Section 409A Regulations Facilitate Common Pay Practices

The Internal Revenue Service (IRS) has proposed a number of updates to current regulations governing nonqualified deferred compensation under Section 409A of the Internal Revenue Code of 1986, as amended. The proposed updates...more

BCLP

Good News! New 409A Regulations (Yes, Really!) – Part 1: Firing Squad

BCLP on

On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Grisly Death of Determination Letters for Individually Designed Plans

The Internal Revenue Service (IRS) announced last year that it would end its staggered five-year remedial amendment cycle system for individually designed retirement plans under the determination letter program due to...more

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