Internal Revenue Code (IRC)

News & Analysis as of

Decision on Unitary Group Stands after Michigan Supreme Court Chooses Not to Review

On January 24, 2017, the Michigan Supreme Court denied the application filed by the Michigan Department of Treasury (the "Department") for leave to appeal the Court of Appeals' published decision in LaBelle Management v...more

Stretch out estate tax on business interests

Frequently, heirs of successful entrepreneurs are forced to sell off business interests at “fire sale” prices to help pay federal estate taxes. To alleviate the tax strain, Internal Revenue Code Section 6166 allows heirs to...more

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

IRS Updates Golden Parachute Audit Guide

This is our first of many alerts during 2017 as the new administration signals the rollback of many regulations (e.g., fiduciary rules and pay ratio). We will keep you posted. In January 2017, the Internal Revenue...more

White House Urges Suspension of DOL Fiduciary Rule

The future of the fiduciary rule—originally set to be implemented this upcoming April—remains uncertain after the White House directed the United States Department of Labor (DOL) to reevaluate, defer implementation and...more

IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below,...more

No Tax, No Travel

If you are not expecting a refund this year, you may be wondering what taxes have to do with your travel plans. A little over a year ago, Congress passed a law to authorize funding for highways known as “Fixing America’s...more

IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below,...more

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

Treasury Releases Proposed Rules Implementing Partnership Audit Regime; Awaiting Publication in the Federal Register

On January 18, 2017, the Department of Treasury (“Treasury”) released proposed regulations (REG-136118-15) (the “Proposed Regulations”) implementing the partnership audit provisions of the Bipartisan Budget Act of 2015 (the...more

IRS Issues New Guidance on TIGER Grants

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services. Section 118...more

Public Finance Advisory: IRS Releases Clarifying Management Contracts Rules

For the third time in as many years, the Internal Revenue Service (the “IRS”) has issued guidance for determining whether a management contract will result in private business use for property financed with governmental or...more

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

Keeping Your Family Foundation in Compliance

The 2016 election cycle made front page news of certain failures in compliance by both the Bill, Hillary & Chelsea Clinton Foundation and The Donald J. Trump Foundation. Every new year brings new goals and, for every family...more

DSU Plans Require Careful Review to Avoid Adverse U.S. Tax Treatment

A Canadian company is planning to adopt a deferred share unit plan (DSU plan) for its directors. Only one or two of its directors are U.S. citizens or U.S. residents (“U.S. Directors”). With only one or two U.S. Directors,...more

Six Tips for Tribal Governments to Reduce Tribal Member Taxes in 2017

As the Republican-led Congress and White House move forward on the repeal of the Affordable Care Act (ACA) and major tax-reform legislation, there are several new opportunities that may benefit tribal governments and their...more

Derivatives In Review - January 2017

Regulation AT – An Update - From the time Regulation AT was initially proposed by the CFTC over a year ago, the CFTC has solicited and considered numerous comment letters, held a public roundtable, supplemented the...more

Employee Benefits Developments - January 2017

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of January, 2017. Click through the links below for more information on each specific development or case. IRS...more

IRS Issues New Guidelines for Qualified Management Contracts for Facilities Financed with Tax Exempt Bonds

Health care providers with facilities financed with tax exempt bonds need to be aware of recent changes to the IRS rules for qualified management contracts. On August 22, 2016, the IRS issued Rev. Proc. 2016-44 which...more

IRS Releases New Management Contract Rules

On January 17, 2017, the Internal Revenue Service (IRS) released Revenue Procedure 2017-13 (2017-13). This revenue procedure modified, amplified, and superseded Revenue Procedure 2016-44 (2016-44), which was just issued last...more

Highlights of Record Retention Requirements Applicable to Employee Benefit Plans

In the presentation “Highlights of Record Retention Requirements Applicable to Employee Benefit Plans,” Todd A. Solomon detailed the general rules of The Employee Retirement Income Security Act of 1974 (ERISA). He discussed...more

IRS Releases Final Treasury Regulations on MLP Qualifying Income

On January 24, 2017, the Internal Revenue Service (IRS) issued final regulations addressing master limited partnership (MLP) qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code (the Code). The...more

Alert: Year-End Reporting for ISOs and ESPPs

This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to incentive stock option exercises and transfers of stock...more

Second Circuit Affirms Dismissal of Mortgage-Backed Securities New York State False Claims Act Case Against Wells Fargo

In New York ex rel. Jacobson v. Wells Fargo National Bank, N.A., 824 F.3d 308 (2d Cir. 2016), the Second Circuit affirmed the dismissal of a relator’s tax fraud-based claim against Wells Fargo under the New York False Claims...more

You Lost Your Case to the IRS: Are Accountant and Lawyer Fees Deductible?

Section 212(3) of the Internal Revenue Code [Code] provides in pertinent part: “In case of an individual, there shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year...more

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