Income Taxes Internal Revenue Service

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
News & Analysis as of

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Enforcement of Foreign Tax Claims

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

South Carolina Tax Amnesty for 2017?

The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more

2016 Year-End Tax Update: Okay, Now What?

In last year’s materials, loosely styled “Make America Great Again!,” we ruminated upon (and also thought about) what role, if any, federal income taxes might play in helping to make America great again, once the interminable...more

IRS Rules That Syndicated Conservation Easements With Inflated Appraisals Are Listed Transactions

In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more

U.S. Department of Justice Obtains Court Order Authorizing IRS to Investigate Bitcoin Users

Using the same procedure it used to crack the secrecy of Swiss Banks, on November 30, 2016, the U.S. Department of Justice obtained a court order allowing the IRS to issue a “John Doe” summons to Coinbase Inc., the largest...more

IRS Provides Guidance on TLAC

On December 16, 2016, the Internal Revenue Service (“IRS”) issued Revenue Procedure 2017-12 (the “Revenue Procedure”), which provides that certain instruments issued by global systemically important banking organizations...more

Private Client Services 2016 Year-End Advisory

As the year draws to a close, we have entered a period of great uncertainty in estate and tax planning. President-elect Donald Trump has identified tax reform as a priority of his new administration and, with Republican...more

Investment Management Update

IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more

Cuando FATCA y los Programas de Amnistía Fiscal se cruzan, ¿será demasiado tarde para los contribuyentes Estadounidenses?

Instituciones Financieras extranjeras (FFIs) y las autoridades fiscales de los países anfitriones le han proporcionado al IRS con una segunda ronda de informes de información sobre cuentas financieras mantenidas por los...more

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Tax Truths: Volume 1, No. 2 – December 2016

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

Taxes and Divorce

Divorce is tough. Even amicable divorces are financially and emotionally draining. The last thing you need is to have tax problems pop up as a result of divorce proceedings. To avoid such problems here’s a list of some top...more

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

IRS Relaxes Section 83(b) Filing Requirements

A taxpayer who makes a Section 83(b) election to accelerate the income taxation date of certain transferred property is no longer required to file a copy of the Section 83(b) election with his or her tax return for the year...more

Of Course You Should Trust the IRS with Your Financial Information

The income tax provides justification for massive government intrusion into the financial privacy of its taxpayers. Its information gathering capacity and demands run wide and deep, and expand with almost every piece of...more

IRS Appeals Chief Clarifies New Settlement Conference Rules

The IRS recently announced that as of October it will no longer offer in-person or “face-to-face” settlement conferences with its Appeals Officers, except in a few, very limited circumstances. Settlement discussions will now...more

Where Did All The "S" Corporations Come From?

You just formed your medical practice in Alabama, and you either chose a professional corporation (a "PC") or an LLC. If you went with a PC, you get to choose between an "S" corporation ("S corp") or a "C" corporation ("C...more

What Kind of Tax Changes Can We Expect From Trump's Presidency?

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What...more

What Do All These IRS Collection Letters Mean?

When someone owes the IRS taxes, as a result of not paying the tax shown as due on a tax return or where the IRS audits and imposes additional taxes owed, the IRS will “assess” this tax liability, and with penalties and...more

Recaps from Proskauer’s 21st Annual Trick of Treat Tax Exempt Seminar

Proskauer’s 21st Annual Trick or Treat Seminar was held on Thursday, October 27. The Seminar discussed: Best Practices for Document Retention: One Size Does Not Fit All...more

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Substantiation of Charitable Donations

As we enter the giving season and begin making charitable contributions it is important to remember that some gifts require more than just the act of giving to qualify for a charitable tax deduction. For monetary...more

Halloween Tax Alert: Beware of the IRS "Wealth Squad"

What’s scarier than zombies, clowns, or vampires? The dreaded Global High-Wealth Industry Group, a/k/a the IRS’s “Wealth Squad.” The Wealth Squad is comprised of highly-specialized examiners and other professionals whose sole...more

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