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

OECD/BEPS Intangibles Revisions to Change Character, Treatment of Goodwill

Corporations acquiring intangible assets as part of business combination will no longer be able ignore goodwill in their subsequent restructurings and asset transfers. That’s the upshot from tax authorities from around the...more

S.D.N.Y. Judge Permits Novel Theory And Allows SEC To Use Unpaid Taxes As Measure Of Disgorgement In Securities Fraud Case

In a case against Dallas billionaires Sam Wyly and the estate of his late brother, Charles, Judge Shira Scheindlin of the U.S. District Court for the Southern District of New York agreed with the U.S. Securities and Exchange...more

High Net Worth Family Tax Report, Vol. 9, No. 2

What You Need to Know About Corporate Inversions - It seems like every day brings news of another possible corporate inversion transaction. The news reports usually describe these transactions as another United States...more

2015 Predicted Inflation Adjusted Tax Items

The following are some of the more salient tax items adjusted unofficially for inflation by Research Institute of America. While unofficial they represent a very good estimate of predicted adjusted items for 2015. This list...more

Legal Alert: The Tax Court Approves the Use of Predictive Coding

On September 17, the U.S. Tax Court, in Dynamo Holdings LP v. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), held that a taxpayer could use predictive coding, over the objection of the Internal Revenue Service (IRS), to...more

Fifth Circuit Court Reverses Tax Court Ruling on Fractional Interest Valuation Discounts

On September 15, the U.S. Court of Appeals for the Fifth Circuit reversed a 2013 Tax Court decision that had allowed only a nominal, 10% fractional interest discount for artwork included in a decedent’s estate....more

Bit Bites: Latest Legal Developments in Digital Currencies

When Is Bitcoin “Money” Versus a “Security”? In motions involving a high-profile criminal prosecution with ties to Silk Road and a Securities and Exchange Commission (SEC) enforcement action, two federal courts have clarified...more

Treasury Announces Inversion Regulations; Reach Extends to Other Cross-Border M&A

New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions. On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more

IRS and Department of Treasury Release 2014-2015 Priority Guidance Plan

On August 26, 2014, the IRS and the Department of the Treasury issued the 2014-2015 Priority Guidance Plan. The Priority Guidance Plan includes 18 exempt organization law projects and four projects relating to charitable...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in...

For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations...more

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

Legal Alert: IRS Reaches a Split Decision on Rollover Allocation Rules

On September 18, the Internal Revenue Service (IRS) issued Notice 2014-54, which clarifies that, subject to some limitations, a single distribution of pre-tax and after-tax amounts from a qualified retirement plan, a 403(b)...more

Mission Creep Costs A Section 501(c)(3) Organization Its Exemption

A change in function of a Section 501(c)(3) organization results in the IRS revoking its exemption. To receive Section 501(c)(3) status, exempt organizations apply for exemption from the IRS. The exemption application...more

GAO Issues Preliminary Report on Challenges in Auditing Large Partnerships

The Government Accountability Office (“GAO”) recently issued a preliminary report on the challenges in auditing large partnership returns, a copy of which is available here. The GAO issued an interim report earlier this year...more

IRS Expands Permissible Mid-Year Cafeteria Plan Elections

On September 18, 2014, the IRS issued Notice 2014-55, which expands permissible mid-year election changes under “cafeteria plans” to address two specific situations that have arisen in connection with the implementation of...more

Legal Alert: Final Rules on Compensation Deduction Limit for Health Insurers

The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain...more

Department of the Treasury and the Internal Revenue Service to Issue Regulations Limiting Taxpayers’ Ability to Benefit from...

On September 22, 2014 the Department of the Treasury and the Internal Revenue Service provided official notice to taxpayers of their intention to issue regulations limiting taxpayers’ ability to benefit from undertaking...more

Legal Alert: New PPACA-related “Family Status” Changes for Cafeteria Plans

The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more

HEALTH CARE REFORM: Time to get serious about the Affordable Care Act’s employer reporting requirements

The Affordable Care Act (ACA) has consumed us for the last four and a half years. As employers, we have spent so much time trying to figure out what the ACA requires, trying to hit the government’s moving regulatory targets,...more

Alert: IRS and Department of the Treasury Notice Limits Inversion Transactions

On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...more

IRS Finalizes and Clarifies ObamaCare Reporting Rules

The Internal Revenue Service has released a lengthy set of questions and answers regarding the reporting requirements under the Affordable Care Act (“ACA”) for “applicable large employers” under section 6056 of the Internal...more

IRS: Investment Fund Managers are Subject to Self-Employment Tax

The Office of Chief Counsel of the Internal Revenue Service (the "IRS") recently issued internal guidance in the form of a Chief Counsel Advice (the "CCA") indicating that the IRS has taken the position that the "limited...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

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