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

DOL Updates Procedures for Locating Missing Participants in Defined Contribution Plans

The U.S. Department of Labor recently released Field Assistance Bulletin 2014-01 (the “FAB”), which updates DOL’s guidance on locating missing participants when a defined contribution plan, such as a 401(k) plan, is...more

IRS Applies 20th Century Analysis To 21st Century Social Organization

Code §501(c)(7) provides an exemption from federal income tax for clubs organized substantially for pleasure, recreation, and other nonprofitable purposes if no part its net earnings inures to the benefit of a private...more

IRS Denies Exempt Status under Section 501(c)(4) For Too Much Political Activity

Earlier this year, while Washington was fixated on former Internal Revenue Service (IRS) employee Lois Lerner and her missing emails, her former employer quietly denied the application for exemption of an organization seeking...more

Health Care Reform Implementation Update August 2014

The Centers for Medicare and Medicaid Services (CMS) made announcements this week regarding the Open Payments system and the availability of Affordable Care Act (ACA) Consumer Assistance Program grant funds, issued a request...more

Draw down bonds and date of issuance: questions remain with IRS guidance

For many years multifamily housing apartment projects could be financed with tax-exempt drawn-down bonds and loans with all of the bonds issued pursuant to a draw-down loan being treated as part of a single issue. The date of...more

IRS Amends Revenue Ruling 81-100 to Permit Participation in Group Trusts by Puerto Rico Plans and Insurance Company Separate...

The Internal Revenue Service (the “IRS”) issued Revenue Ruling 2014-24 (the “Ruling”). The Ruling amends Revenue Ruling 81-100, the ruling that established the requirements applicable to a tax-qualified group trust. The...more

IRS Finalizes Guidance on Rev. Rul. 81-100 Group Trusts, and Insurance Company Separate Accounts

In Rev. Rul. 2014-24, scheduled for publication on September 8, 2014, the Internal Revenue Service (the Service) substantially completed its pending guidance on Rev. Rul. 81-100 group trusts by permanently authorizing the...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for...

The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more

California Federal Court Holds Bank Responsible For Funds Subject To IRS Levy On Customer’s Account

On August 15, the U.S. District Court for the Central District of California held that a bank responded too slowly to a government levy on a customer’s account and was therefore responsible for funds subsequently removed by...more

IRS Clarifies and Expands "Beginning Construction" Tests for Production Tax Credit and Investment Tax Credit

In 2013, the Internal Revenue Service established two “beginning construction” tests – a physical work test and a 5% safe harbor test – to determine eligibility for the production tax credit (PTC) and investment tax credit...more

IRS Releases New Guidance on Beginning of Construction

The IRS recently released Notice 2014-46 (the Notice) which provides welcome guidance to tax equity investors and developers on the construction of wind, geothermal, biomass, landfill gas and certain hydropower and marine...more

What Does a Fiduciary Do When Advised of an Offshore Account?

On June 18, 2014 the IRS announced changes to the Offshore Voluntary Disclosure Program (OVDP). The changes include the following...more

IRS Comments on its PTC Start of Construction Guidance

On August 20, the American Wind Energy Association (AWEA) held a webinar to discuss Internal Revenue Service (IRS) Notice 2014-46, which clarified the rules for wind projects to be grandfathered for production tax credit...more

Splits Are Not the Best for Business: Uncertainty after Conflicting Decisions on the Scope of Obamacare Subsidies

The recent decisions by the Fourth Circuit and the D.C. Circuit address a controversy that could have far-reaching consequences for the Patient Protection and Affordable Care Act (the “ACA”). Under the ACA, states and the...more

IRS Ruling Creates Opportunities for Tax Savings by Companies With Substantial Real Estate Assets

On July 29, Windstream announced that it plans to spin off certain telecommunications network assets into an independent, publicly traded real estate investment trust (REIT). Windstream made the announcement after it obtained...more

Notice 2014-46 Provides Additional Guidance on Eligibility of Wind and Other Renewable Energy Facilities for the PTC or the ITC

On August 8, 2014, the Internal Revenue Service (IRS) released Notice 2014-46 (the “Notice”), which provides some important clarifications with respect to the requirement that construction of a project commence prior to...more

IRS Notice 2014-46 clarifies guidance for Production Tax Credits and Investment Tax Credits

The American Taxpayer Relief Act of 2012 modified the definition of certain “qualified facilities” under Section 45(d) of the Internal Revenue Code to require that the construction of such facilities must begin prior to...more

An Appreciation for Hedging Your Bets on Deferred Compensation

Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more

Forget About Hiding Money Offshore!

On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters”...more

IRS Releases New Guidance on Beginning of Construction - Aug 2014

On August 8, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-46 (the “Notice”), which clarified certain aspects of the beginning of construction requirement that must be satisfied for taxpayers to qualify for...more

IRS Issues Additional Guidance with Respect to 2013 Beginning of Construction Rules for Wind and Other Renewable Projects

The Internal Revenue Service (Service) issued Notice 2014-46 (Notice) on August 8, 2014, to provide further guidance on meeting the beginning of construction requirements for wind and other qualified facilities (biomass,...more

Additional IRS Guidance on Physical Work Test and Facility Transfers for Energy Tax Credits

The IRS has released additional guidance (Notice 2014-46) on the “beginning of construction” requirement for the renewable energy production tax credit under Code Section 45 (PTC) and energy investment tax credit under Code...more

‘F’ Reorganization Is Not An Inversion Transaction

The hot tax policy discussion these days is about corporate inversions. Rather than entice capital to stay in the U.S. with favorable tax rates (i.e., using the carrot), it is being proposed to enhance corporate inversion...more

Tax Policy, IRC 1031 and Politics

This post is the first part of a two-part post describing a vital tax provision, IRC 1031. Part 1 will outline its operation and perceived benefits, while Part 2 will present some of the more common arguments against its use,...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

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