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

Bill Introduced to Repeal Cadillac Tax

A bill has been introduced in the House of Representatives that would repeal the “Cadillac Tax” provision of the Affordable Care Act (codified in Internal Revenue Code Section 4980I). The Cadillac Tax provision imposes an...more

IRS Continues to Expand, Encourage and Simplify Correction Program in 2015 Updates to EPCRS

In spite of a plan sponsor's best efforts, errors and failures in administering a retirement plan occasionally come to light. We hear about these errors and failures usually following a change in administration, service...more

IRS Presses Pause on Issuing Rulings

The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically, the IRS may hit pause on...more

OECD Discussion Draft on Cost Contribution Arrangements vs. US tax rules on Cost Sharing Arrangements: key comparisons

The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises. This...more

United States Tax Court, Bob R. Davis and Erin Davis, Petitioners v. Commissioner of Internal Revenue, Respondent (Published...

Shareholder Marcus Brooks served as lead counsel in Bob R. Davis and Erin Davis, Petitioners v. Commissioner of Internal Revenue, Respondent. The case involved a charitable deduction for a bargain sale to a public charity....more

Commercial Restructuring & Bankruptcy News - May 2015, Issue 2

In This Issue: - How Safe are the Bankruptcy Code Safe Harbors? - Stockton’s Chapter 9 Plan Approval - Delaware Chancery Court Clarifies Fiduciary Duties of Insolvent Corporation Directors in Derivative...more

More and Less Expensive Options for Retirement Plan Corrections: New IRS Guidance on EPCRS

In This Issue: - Rev. Proc. 2015-27 - Rev. Proc. 2015-28 - For More Information - Excerpt from Rev. Proc. 2015-27: Rev. Proc. 2015-27 may be used beginning March 27, 2015 and is effective July 1,...more

IRS Limits Correction Opportunities under Section 409A Proposed Income Inclusion Regulations and Imposes 20% Penalty

In Chief Counsel Advice 201518013 (May 1, 2015) (the "CCA"), the IRS addresses an executive retention bonus that originally vested after three years and was payable in equal installments on the first two anniversaries of the...more

Department of Justice Reprioritizes Asset Seizure in Structuring Cases But Risks Remain

On December 23, 2014, the United States Attorney for the Eastern District of North Carolina filed a Complaint for Forfeiture In Rem seeking to forfeit $107,702.66 belonging to Lyndon McLellan, the owner of L&M Convenient Mart...more

Commercial Restructuring & Bankruptcy Alert - May 2015

In this issue: - How Safe are the Bankruptcy Code Safe Harbors? - Stockton’s Chapter 9 Plan Approval - Delaware Chancery Court Clarifies Fiduciary Duties of Insolvent Corporation Directors in Derivative...more

The ACA’s Toyota tax

For several years now, employers have spent a great deal of time focusing on the Affordable Care Act’s (ACA) play-or-pay mandate. Numerous articles have been written and numerous educational seminars have been given...more

IRS Rules Retention Arrangement Violates 409A

In a Chief Counsel Memorandum issued last month, the IRS concluded that an executive retention arrangement violated Section 409A despite the employer’s efforts to correct the arrangement before the retention bonus vested....more

DOL Re-Proposes Fiduciary Rule

On April 14, 2015, the U.S. Department of Labor (DOL) re-proposed its rule expanding the definition of fiduciary. A re-proposed fiduciary definition was initially released in October of 2010, but the Department of Labor...more

Chief Counsel Memorandum Clarifies IRS Position on Informal 409A Corrections

On May 1, the IRS released a Chief Counsel Memorandum that clarifies the IRS’ position with respect to the correction of deferred compensation arrangements outside of the IRS’ formal Section 409A correction programs....more

ESMA Publishes Clearing Obligation CP for Additional IRS Classes

On May 11, ESMA published a consultation paper (CP) on the clearing obligation for additional classes of interest rate derivatives, including fixed-to-floating interest rate swaps denominated in Czech Republic koruna (CZK),...more

Employee Misclassification in the Entertainment Industry

Employee misclassification is one of the leading labor abuses in the country. In fact, in recent years, both the Internal Revenue Service and the U.S. Department of Labor have launched a misclassification initiative to combat...more

IRS Announces Potential Changes to Determination Letter Program

The commissioner for the Tax Exempt and Government Entities Division of the IRS stated during a recent conference that the IRS plans to change its determination letter program in 2017. Individually designed plans are...more

IRS Provides Penalty Relief for Incorrect or Delayed Forms 1095-A

The IRS issued Notice 2015-30, which provides penalty relief for taxpayers who received an incorrect or delayed Form 1095-A. Form 1095-A is provided to all individuals who enrolled in health insurance coverage through the...more

Silver Tsunami Quickly Approaching Department of Revenue Thanks to Early Retirement Incentive Program

On May 4, 2015, Governor Charlie Baker signed into law a bill creating an early retirement incentive program for Massachusetts state employees. Under the incentive plan, employees choosing to retire effective June 30, 2015,...more

Uses of Suspicious Activity Reports by the IRS

In a recent conference the Director of the Financial Crimes Enforcement Network (FinCen) discussed the use of Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's) which are required to be filed by...more

Compensation and Benefits Insights – April 2015 #2

The IRS recently made helpful revisions to the Employee Plans Compliance Resolution System ("EPCRS). EPCRS is an IRS program that permits plan sponsors to correct certain retirement plan errors and avoid substantial...more

New Temporary and Proposed Regulations Offer Welcome Clarification on Application of the Embedded Loan Rule

On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to...more

Internal Revenue Service Announces Creation Of A Criminal Investigative Team To Focus On Cyber Tax Fraud

A May 5, 2015 report detailed that the Internal Revenue Service (“IRS”) has created a new cybercrime investigation team. Based in Washington, D.C., and made up of about a dozen specially-trained agents, the unit will focus...more

Does Your Retention Bonus Plan Violate IRS Code?

In a memorandum released earlier this month, the IRS Office of Chief Counsel ruled that a retention bonus payable to an executive violated Section 409A of the Internal Revenue Code ("409A"). The IRS further ruled that the...more

Tax Alert: IRS Untangles Section 163(L) in Cross-Border Hybrid Financing Transaction

“In terrorem” or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in 1997, is no exception, so that even now certain fundamental questions relating...more

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