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

IRS Formalizes Transcripts as Substitute for Estate Tax Closing Letters

In 2005, I discussed how the IRS had posted information on its website that an account transcript notation bearing transaction code “421” could be used to determine that the IRS had concluded its review of a filed estate tax...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Will Trump Administration Curb the Recent Targeting of Independent Contractors?

A critical but unresolved issue for the motor carrier industry is the continuing viability of the independent contractor truck driver model, which is under siege by state and federal regulatory agencies as well as private...more

Loans Between Related Entities

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

Split Dollar Shing-a-Ling! Employing the Concepts of Inter-Generational Split Dollar in Compensatory Split Dollar Arrangements

Overview - In the last ten years, life insurance producers and their counsel have quietly transferred great fortunes with minimal gift and estate taxation using intergenerational split dollar life insurance programs....more

Employee W-4 Forms

Employers are required to obtain a signed IRS Form W-4 when hiring a new employee. Although Form W-4 is revised each year by the IRS to reflect current tax rates, exemption amounts, etc., the form remains valid until an...more

Phishing Scam Targets HR Professionals By Seeking W-2s

With the new year upon us, cyberthieves are once again attempting to prey on unwitting HR professionals, as my colleague William Roberts explained in an article last week for SHRM on phishing. The scam goes like this. As...more

Grant to Public Charity Qualifies as “Unusual Grant” for Public Support Test

Publicly supported charities provide favorable benefits under the Code for both the organization and donors, in contrast with non-publicly supported private foundations. To qualify, the organization must receive a substantial...more

Enforcement of Foreign Tax Claims

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

Tax Season Is in Full Swing: Beware of the W-2 Spear Phishing Scam

Last year we saw an unprecedented number of companies of all sizes fall victim to a W-2 spear phishing scam. The scam usually began with a “spoofing” email that appeared to have been sent by a company’s CEO or CFO to one or...more

The PFIC Regulations Get a Facelift

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

Certain Information Statements for ISOs and ESPPs Due by January 31, 2017

As reported in Part 1 of our 2016 End of Year Plan Sponsor “To Do” List, Section 6039 of the Code requires employers to provide a written information statement to each employee or former employee and file information returns...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

Estate Administrative Update: IRS Notice Confirms Account Transcripts May Serve as Estate Tax Closing Letter

Recently, the IRS issued Notice 2017-12, providing further guidance on ways to confirm that the IRS has closed its examination of an estate tax return. Notice 2017-12 officially confirms what the IRS website has said for...more

Executive Compensation Alert: IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers

This Client Alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the “Code”), with respect to stock issued to employees (or former...more

501(c)(3) Public Charities Subject to New Donor Disclosure Requirements in New York

Since 1958, when the Supreme Court held that the State of Alabama’s attempt to compel the NAACP to disclose its membership lists infringed on the members’ constitutional rights to freedom of speech and assembly, charities and...more

Advisors Advantage - January 2017

How An RIA Can Profit Off Of The New Fiduciary Rule. It's an opportunity. When it comes to an industry, change is often fraught with trepidation and fear. However, I always believe that change also brings...more

What does 2017 have in store for blockchain technology?

Many are expecting 2017 to be a great year for blockchain technology. As 2017 began, the price of Bitcoin, one of the most-recognized digital currencies using blockchain technology, rose to over $1,000 in the wake of market...more

Are Individually Designed Retirement Plans Destined to Become Dinosaurs?

The Impact of Changes to the IRS Determination Letter Program - This January 2017 will see the last regular IRS determination letter applications filed for individually designed retirement plans. After this final Cycle A...more

Employers: 2017 deadlines approach to furnish incentive stock option and employee stock purchase plan information statements and...

Section 6039 of the Internal Revenue Code (Code) requires a corporation to furnish a written statement to any employee or former employee who either (i) exercised an incentive stock option within the meaning of Section 422 of...more

Treasury Department Unofficial Statements on Proposed Section 2704 Regulations

There is a lot of uncertainty whether the Section 2704 proposed regulations will ever be finalized, either due to policy to be set by President-elect Trump, and/or Congressional efforts to block those regulations....more

When Investing In A Partnership May Be A Tax Problem

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

[Webinar] Self-Employment Tax and LLCs; New Partnership Audit Rules; Selected Issues from Heckerling - Jan. 24th, 12:00pm CT

In the webinar we will analyze a recent IRS memo delineating between when it will and will not respect efforts to make a member of an LLC subject to self-employment tax. We will become sensitized to how upcoming partnership...more

Why are Americans Working Abroad Giving Up Citizenship?

Many Americans working abroad are renouncing their citizenship because of tax requirements imposed by U.S. tax laws. For Illinois residents employed overseas, an immigration lawyer in Chicago can explain tax laws that have an...more

South Carolina Tax Amnesty for 2017?

The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more

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