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Fees Internal Revenue Service

Woodruff Sawyer

Reminder: PCORI Fees Due By July 31, 2024

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Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2024 deadline for paying fees that fund the Patient-Centered Outcomes...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Spring Edition | 2024

On March 27, 2024 the Vermont Captive Insurance Association (VCIA) held its biannual “Roadshow” educational event designed for prospective captive insurance companies. The Roadshow, which has been hosted in over 20 cities,...more

Alston & Bird

IRS Signals Increased Scrutiny of Deductibility of Success-Based Fees in M&A Transactions

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Our Tax Group sheds light on recent IRS rulings that disallow deductions involving success-based fees in M&A transactions. Contrary to common practice, the IRS recently ruled target companies could not deduct success-based...more

Holland & Hart - The Benefits Dial

ERISA, ERISA…Just an Old Sweet Song Keeps ERISA on my Mind

“Georgia” on your mind? As we look towards the upcoming Masters golf tournament weekend, our minds turn to the condition of the greens (exquisite), the players tee off order (does afternoon help or hinder Tiger on an expected...more

Hall Benefits Law

Federal Agencies Issue Final Rules on Federal IDR Process Administrative Fee and Certified Entity IDR Fee Ranges

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The Internal Revenue Service, Employee Benefits Security Administration, and the Centers for Medicare & Medicaid Services (collectively, “the Departments”) recently issued final rules concerning fees established by the No...more

Carlton Fields

IRS Gives Equal Billing to an Adviser Life Insurance Contract: Treats Adviser’s Fee the Same as Under Adviser Annuities

Carlton Fields on

The IRS recently published a private letter ruling (No. 202341002) dealing with the tax treatment of advisory fees paid to an adviser from an “adviser life insurance contract.” Specifically, the letter ruling addressed...more

Arnall Golden Gregory LLP

The Pitch - October 2023

The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more

Groom Law Group, Chartered

IRS Increases PCORI Fee

On October 18, the IRS issued Notice 2023-70, which increased the PCORI fee from $3 per covered life to $3.22 per covered life for policy and plan years that end on or after October 1, 2023 and before October 1, 2024....more

Woodruff Sawyer

Compliance Alert: IRS Releases PCORI Fee For Plan Years Ending Before October 1, 2024

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The IRS has released Notice 2023-70, which sets the applicable PCORI fee for plan years ending between October 1, 2023 and September 30, 2024 at $3.22 per covered life....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Fee disclosures can be improved

The fee disclosure regulations were one of the best things that ever happened to the retirement plan business. Yet, what is great, can be improved....more

Ward and Smith, P.A.

Mo Money, Mo Problems? No Biggie for a Homeowner's Association, Right?

Ward and Smith, P.A. on

Was your community association lucky enough to come in under budget last year? On the surface, this might appear to be a bonus, but if not handled properly, it can quickly turn into an unexpected tax burden. ...more

Allen Barron, Inc.

IRS Warns of Shady Tax Preparers and Increased Audit Risk

Allen Barron, Inc. on

In a recently released bulletin, IR-2023-59, the IRS warns of shady tax preparers and increased audit risk as part of their “Dirty Dozen” series.  The IRS provided some common “warning signs” including tax preparers who base...more

Kramer Levin Naftalis & Frankel LLP

IRS Denies Deductibility of Sell-Side Advisory Fees

In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more

Faegre Drinker Biddle & Reath LLP

Managing IRAs: Charging Different Fees for Different Investments

Registered investment advisers, including dual registrant broker-dealers (collectively “advisers”) who provide discretionary investment management services to individual retirement accounts (IRAs), are fiduciaries under the...more

Verrill

Health Plans: PCORI Fee Is Due August 1, 2022

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What is the PCORI Fee? The Affordable Care Act created a non-profit corporation, the Patient-Centered Outcomes Research Institute (“PCORI”), to conduct research to help individuals, providers, and policymakers make better...more

Dickinson Wright

Success-Based Fees: Elect the Safe Harbor or Document Thoroughly

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When taxpayers pay fees contingent on the successful closing of certain “covered transactions,” including, for example, taxable acquisitions of assets that constitute a trade or business, such “success-based fees” must be...more

Bass, Berry & Sims PLC

Reminder – Annual Deadline (typically, July 31) to Report and Pay PCORI Fee is Approaching

Bass, Berry & Sims PLC on

The annual filing (and fee payment) for applicable self-insured health plans and specified health insurance policies used to fund the Patient-Centered Outcomes Research Institute (the PCORI fee) is soon coming due—this year,...more

McDermott Will & Emery

Weekly IRS Roundup November 23 – November 27, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020... November 23, 2020: The IRS released TD 9935, providing...more

McDermott Will & Emery

Are Crypto Loans Taxed as Loans?

Transactions involving the borrowing and lending of units of virtual currency (or crypto loans) are increasing in number and type. Lacking Treasury or IRS guidance with respect to crypto loans, potential tax issues that arise...more

Seyfarth Shaw LLP

Don’t Miss The July 31 Deadline

Seyfarth Shaw LLP on

Seyfarth Synopsis:  The IRS announced the new rate for calculating the PCORI fee and provided some transition relief, but did not extend the deadline of July 31st for paying the fee. In May, the IRS issued Rev. Proc. 2020-32...more

Bass, Berry & Sims PLC

Reminder – Annual Deadline (July 31) to Report and Pay PCORI Fee is Approaching [Again!]

Bass, Berry & Sims PLC on

Yes, that PCORI Fee—it’s back! About this time last year, we let you know that this filing and fee was coming due, and that it was the last time it would be required for a calendar year plan. Since that time, however, the...more

BCLP

Electronic Form 1023 news, social media reminder and more

BCLP on

Form 1023 Paper Submission Transition Period Expires April 30 - As of January 31, 2020, organizations are required to submit Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal...more

Holland & Hart - The Benefits Dial

You’ve Got Another PCORI Fee Coming!: Congress revives the PCORI fee and filing obligations

In the wee hours of December 2019, Congress revived the PCORI fee and filing obligations of employer sponsors of self-insured group health plans. In accordance with the requirements of the Affordable Care Act, employer...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Determined a Subsidiary Stock Sale Does Not Make Prior Capitalized Transaction Costs Deductible

A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more

Burr & Forman

PCORI Fee Resurrected

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In the summer of 2019, I wrote a short blog on the death of the PCORI fee — Ding, Dong, the PCORI Fee is Dead!. When enacted as part of the Affordable Care Act, the fee was set to expire with plan/policy years ending after...more

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