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

Proposed Treasury Regulations Address Private Equity Management Fee Waivers and Profits Interests

The Internal Revenue Service ("IRS") and Treasury Department recently released proposed regulations under section 707(a)(2)(A) of the Internal Revenue Code of 1986 (the "Code) addressing the issuance of certain interests in...more

Beware of Traps for the Unwary in Preparing ACA Information Returns (Part 2)

This is part two of a series of posts highlighting traps for the unwary in preparing information returns required under the Affordable Care Act (ACA). As mentioned in part one, information statements must be furnished to...more

The IRS Continues to Face Significant Budgetary Constraints—What Does It Mean To Taxpayers?

The Chief Financial Officer’s Act of 1990 (“1990 Act”) was signed into law by President George H.W. Bush on November 15, 1990. One of the major goals of the 1990 Act was to improve the financial management and to gain better...more

Applying The "Common Legal Interest" Privilege In The Context Of A Financial Transaction

Sophisticated and complex commercial litigation and criminal investigations often involve many participants and their lawyers. In these cases, it is often beneficial for the lawyers to share confidential information pursuant...more

Wait’s Over: IRS Says Waiting Time Penalties Aren’t Wages

We’ve long known that California law does not treat Labor Code Section 203 penalties as “wages.” Earlier this year, the IRS published its view on how to treat those penalties (often referred to as “waiting time penalties” or...more

Treasury and IRS Issue Additional Inversion Notice

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

2016 Cost of Living Adjustments

The Internal Revenue Service has announced the 2016 cost of living adjustments to various limits. The adjusted amounts generally apply for plan years beginning in 2016. Some of the adjusted amounts, however, apply to calendar...more

ABLE Programs and Beneficiaries Boosted by Helpful Guidance from IRS and Social Security Administration

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 (ABLE Act), one of the few recent examples of bipartisan cooperation on a new category of tax and budget expenditure, is both well-intentioned in its...more

IRS Issues Guidance on the Applicability of Section 162(m) to CFO Compensation

Summary: The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code...more

Top takeaways from the 2015 Las Vegas Marijuana Business Convention

Joan Lebow, Carl Rowley, and Fred Roth of Thompson Coburn's cannabis practice attended Marijuana Business Media’s 2015 Marijuana Business Conference at the Rio Hotel, Las Vegas, where more than 5,500 attendees attended...more

Congress Passes New Partnership Audit Rules - The Bipartisan Budget Act of 2015

On November 2, President Obama signed the Bipartisan Budget Act of 2015 into law, which brought sweeping changes to the partnership audit rules. The act repeals the substantive tax provisions and voluntary centralized audit...more

New Rules Encourage Use of P3s

The recently released Internal Revenue Service (IRS) rules in the final allocation and accounting regulations encourage the use of public-private partnerships (P3s). Under these rules, a private party can form a partnership...more

Health Update - November 2015

Best Practices for Using Social Media in Healthcare: Maximizing Impact, Mitigating Risk - Editor's note: In a generation more likely to seek health information online than see a doctor, social media is playing an...more

What's Your Audit Risk? It Depends!

Taxpayers who are considering one of the Streamline Procedures (Non-resident or Resident) have been advised by the IRS that their returns are subject to the regular audit selection process even though they must identify their...more

Is the Charitable Deduction for Trusts Limited to Adjusted Basis?

No, says a U.S District Court. An irrevocable trust received distributions from a partnership in one year and purchased property. In a later year it contributed the property to a qualified charity, after the property...more

IRS Issues More Anti-Inversion Rules

Following on its prior Notice 2014-52 anti-inversion guidance, the IRS has issued new Notice 2015-79 to further limit (i) inversion transactions that are contrary to the purposes of the Section 7874 anti-inversion rules and...more

Your daily dose of financial news The Brief – 11.20.15

The US Treasury Department and IRS are joining forces to address corporate tax inversions with the introduction of new measures aimed at “curtailing companies’ ability to avoid United States tax rates if they move to...more

Helpful News from IRS on Student Loan Bonds

On November 13, the IRS issued Notice 2015-78, providing favorable guidance on topics of interest to providers of “supplemental” or “alternative” student loans financed with tax-exempt bonds and to underwriters of such...more

Can Correction of a Scrivener’s Error Retroactively Fix a Tax Problem with a Trust?

Yes, in a recently released Private Letter Ruling in regard to an irrevocable trust. There were actually two problems with the trust. First, the settlors retained powers to change the beneficial interests of the trust,...more

Prepaying Tuition Payments To Qualified Educational Organizations

It is becoming more common for wealthy individuals to prepay the tuition expenses (which do not include books, supplies, dormitory fees, board or other similar expenses), on an annual basis or for multiple years, for family...more

The IRS Releases The Benefit Plan Limitations For 2016, Most Limits Remain The Same

The Internal Revenue Service (IRS) recently announced the annual inflation adjustments for 2016 for qualified retirement plans, fringe benefits and health plans. This information may be found on the IRS' website and in...more

Focus on Tax Controversy and Litigation - Second Circuit Determines that Tax Memo Shared Between Taxpayers and Banks Is Protected...

In addition to the discussion of the Second Circuit’s decision in Schaeffler, this month’s issue features articles regarding the “new” IRS Notices covering “Basket Options” and “Basket Contracts”, the Tax Court’s recent...more

New Rules Adopted for IRS Partnership Tax Audits

The Bipartisan Budget Act of 2015 signed by the President Obama on November 2, 2015, creates a new IRS audit regime for all entities treated as partnerships for federal income tax purposes, including partnerships and limited...more

Deadline Approaches to Execute a Cafeteria Plan Amendment for IRS Notice 2014-55

This is a re-issued advisory reminding health plan sponsors that if you have administered your cafeteria plan in accordance with this guidance, make sure to execute a formal plan amendment by the end of the 2015 plan year...more

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