News & Analysis as of

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.  

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect....more

Get Ready for “On The Motion to Amend the Amendment of the Amendment of the Amendment …”

by Balch & Bingham LLP on

The “Discussion Draft” released June 22, 2017 by the Senate Budget Committee carries the House Bill number (H.R. 1628) of the American Health Care Act, and kills taxes like the House bill, but there are major differences,...more

Applicable Federal Rates - July 2017

by Charles (Chuck) Rubin on

Please see full charts below for more information....more

Reissuance of Proposed Regulations on Partnership Audit Rules

by Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

2017 Security Breaches: Frequency and Severity on the Rise

by Revision Legal on

We are only six months into 2017, and we can already tell that it is going to be a bumper year with regard to instances of data security breaches. Looking back at the hacking statistics from 2015 and 2016, we should not be...more

Tax-Exempt Does Not Mean Exempt From Filing Tax Returns

May 15 was the filing deadline for nonprofits operating on a calendar year that are required to file Form 990-series information returns. Many nonprofits mistakenly believe that they are not required to file returns with the...more

Valuation of Illiquid Portfolio Investments – Avoiding Regulatory Risks with Form and Substance

For private fund managers, the valuation of privately-held securities has been subject to heightened regulatory scrutiny. As the IPO on-ramp for private “unicorn” investments has lengthened, fund managers may hold illiquid...more

IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

by Morrison & Foerster LLP on

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Estate Administration Update: A Simplified Procedure for the Portability Election

by Williams Mullen on

Recently, the IRS issued Revenue Procedure 2017-34 (the “Revenue Procedure”), providing a simplified process for certain estates requiring an extension of time to make a portability election under § 2010(c)(5)(A) of the...more

Severance Agreements – Three Tax Traps for the Unwary

by Foley & Lardner LLP on

Severance agreements – especially severance agreements for terminating executives – are ripe with potential tax planning challenges and opportunities....more

PCORI Fee Due by July 31, 2017

by McDermott Will & Emery on

The Patient-Centered Outcomes Research Institute (PCORI) fee was established under the Affordable Care Act (ACA) to advance comparative clinical effectiveness research. The PCORI fee is assessed on issuers of health insurance...more

Is Your Partnership Ready For IRS Audit Changes?

Businesses across the nation are buzzing about Congressional action on tax reform - action that may not even occur. And yet, many partnerships and limited liability companies (LLCs) have not yet delved into significant IRS...more

IRS Grants Extension Of Time To Acquired Group To Elect To Deduct 70-Percent Of Their Success-Based Advisor Fees

by Roetzel & Andress on

In Private Letter Ruling 201722002 (published June 2, 2017), the Internal Revenue Service (IRS) granted the taxpayer, a group of corporations that were acquired pursuant to a plan and agreement of merger and became wholly...more

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

by Foodman CPAs & Advisors on

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Proposed Regulations Re-Released for Centralized Partnership Audit Rules

by Locke Lord LLP on

New partnership audit rules enacted into law on November 2, 2015 (the “Centralized Partnership Audit Rules”) (previously discussed in our QuickStudy: Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and...more

IRS Warns Consumers Of New Phone Scam Just As Private Collectors Get To Work

by Fox Rothschild LLP on

Earlier this year we wrote that the Internal Revenue Service is moving forward with its controversial “Private Debt Collection” program amid a sharp uptick in instances of fraud by scammers posing as legitimate IRS debt...more

Client Reminder: PCORI Payment Due July 31st

by Fraser Trebilcock on

Patient-Centered Outcomes Research Institute (PCORI) Fee / Comparative Effectiveness Fee: Reminder: Plan Sponsors of Applicable Self-Funded Health Plans Must Make PCORI Fee Payment By July 31, 2017. Please let this serve...more

Estate Planning and Prenuptial Agreements: Tax Implications of Alimony

by McNair Law Firm, P.A. on

When contemplating marriage and estate planning, frequently, individuals will enter into prenuptial (premarital) agreements to address their rights and obligations during the marriage and in the event of a divorce or death. A...more

IRS Can Pursue “Responsible Persons” for Unpaid Trust Fund Taxes and Automatic Stay Cannot Be Used to Enjoin Collection Against...

The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more

The Rise of the Group Health Insurance Captive

With its “employer mandate”—i.e., the requirement that applicable large employers make an offer of group health coverage to substantially all full-time employees or face the prospect of a penalty—the Affordable Care Act (ACA)...more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

ICAP: It's Not a TRAP

by Alston & Bird on

An IRS official recently stated that the United States will participate this fall along with several other countries in a pilot of the “international compliance assurance program (ICAP). ICAP is a “tax risk assessment...more

IRS Re-Releases Partnership Audit Regulations

The IRS has released proposed regulations implementing the new centralized partnership audit rules. These regulations are virtually identical to the regulations that were released and then pulled in January of this year. ...more

SEIA’s Finance & Tax Seminar Soundbites

Below are soundbites from panelists at the Solar Energy Industries Association’s (SEIA) Finance & Tax Seminar in New York City. The seminar was held on June 1 and 2, but only comments from the second day are reflected below....more

IRS Reminds U.S. Taxpayers Living Abroad of Misc. Filing Due Dates and Filings

by Charles (Chuck) Rubin on

In News Release 2017-105, the IRS reminded U.S. taxpayers living abroad: The extended due date, if the taxpayer had his or her tax home and abode abroad on the original due date, is June 15. But interest on taxes runs from...more

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