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.
Hot Topics for Waste-to-Energy Investors and Developers
On June 6, 2013, the Internal Revenue Service issued Revenue Ruling 2013-14, which concludes that a Fideicomiso or a Mexican Land Trust (MLT) is not taxed as a “trust” for U.S. income tax purposes. While most practitioners...more
Sponsors of 457(b) plans may receive questionnaires aimed at identifying noncompliance issues. On June 3, the Employee Plans Compliance Unit of the Internal Revenue Service (IRS) announced the creation of its Section...more
If you would like copies of an article that is not linked to a PDF file, or if you would like to receive copies of future articles, please contact Rebecca Sprunger at rsprunger@orrick.com. - 03-29-2013 (U.S.) Final...more
In this presentation: - Tax-Exemption Challenges - Bankruptcy Counseling Challenges - Consumer Protection Statutes - Excerpt from Presentation: How did we get here? - Federal and...more
In today’s challenging health care environment, nearly 30 million Americans suffering from various chronic and life-threatening illnesses are underinsured and have difficulty paying their out-of-pocket medical costs....more
The 2010 Affordable Care Act (ACA) includes a number of new taxes and fees to be assessed to pay for many of the new federal health care mandates....more
There is absolutely nothing wrong with having a foreign bank account. The problem comes along when the existence of the account is not disclosed and income associated with the account is not reported....more
As employers plan for paying various health care reform fees, one question that arises is whether the fees owed are tax deductible. In particular, it has been unclear whether the fees paid pursuant the Affordable Care Act to...more
The IRS has released a revised version of Form 720 “Quarterly Federal Excise Tax Return” for sponsors of self-insured health plans to pay annual fees imposed under the Affordable Care Act. The fee for 2013 is $1 per covered...more
The Affordable Care Act (the ACA) established the Patient-Centered Outcomes Research Institute (the Institute) in order to provide comparative clinical effectiveness research data so that patients, health care providers,...more
The Internal Revenue Service (IRS), the Department of Labor (DOL), and the Department of Health and Human Services (HHS), the three federal agencies with primary responsibility for implementing the Affordable Care Act (ACA),...more
As reported in prior Snell & Wilmer publications (See September 2011 Workplace Word, October 2011 Workplace Word and January 9, 2013 Legal Alert), there are numerous reasons why employers need to ensure that they do not treat...more
In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more
For plan sponsors and insurers wondering how to pay the fee for the Patient-Centered Outcomes Research Institute (which is due by July 31, 2013 for calendar year plans), the IRS has revised Form 720 to provide needed...more
Does your district have outstanding tax-exempt bond obligations? If yes, the IRS is interested in...more
The Internal Revenue Service (IRS) has issued an updated version of IRS Form 720 and the instructions. Self-funded group health plan sponsors and health insurers must use this form to report and pay the fee required to fund...more
As you may know the Affordable Care Act imposed a new fee on issuers of individual and group health insurance policies and plan sponsors of self-funded plans. As previously noted in our blog, on December 5, 2012, the Internal...more
Topics we will cover: • Introduction • Issues with Control Groups • Issues with Prohibited Transactions • Fee Disclosure - Excerpt from Who is in the Control Group? • Aggregation Rules (Section...more
In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more
Since 2009 there have been three offshore voluntary disclosure programs offered by the IRS. The major difference among the three programs is the FBAR penalty, known as the civil miscellaneous penalty. ...more
A significant amount of press attention has been given to an unusual press release filed with the SEC yesterday by Iron Mountain regarding its planned conversion to a real estate investment trust (REIT). Iron Mountain said...more
Several governmental agencies, including the Internal Revenue Service (IRS), Department of Labor (DOL), Securities and Exchange Commission (SEC) and Department of Health and Human Services (HHS), have stepped up their audit...more
Most issuers of healthcare insurance likely have heard about the $500,000 limit on deductible compensation that became effective January 1, 2013, but might be surprised to know how much broader the scope of the deduction is...more
Earlier this week the IRS released the updated Form 720 which plan sponsors and third party administrators must utilize when reporting the Patient Centered Outcome Research Fee....more
On June 6, 2013, the IRS released Revenue Ruling 2013-14, which holds that Mexican fideicomisos or Land Trusts are not trusts for U.S. tax purposes. “Fideicomisos have been an issue in the offshore disclosure world for quite...more
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