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Internal Revenue Service Affiliates

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.  
Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

Holland & Knight LLP on

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Kaufman & Canoles

ESOPs & Employee Benefits Q1 2024 Client Update

Kaufman & Canoles on

On behalf of the ESOPs & Employee Benefits team, we hope you’re enjoying the first days of Spring, when the longer days allow more time to ponder the ever-changing landscape of employee benefits compliance. Please find below...more

Dorsey & Whitney LLP

Initial Guidance for New U.S. Excise Tax on Stock Repurchase Transactions: IRS Substantially Expands Scope of Applicable Canadian...

Dorsey & Whitney LLP on

In our blog post dated August 22, 2022, we discussed the one percent (1%) excise tax on certain stock repurchase transactions by certain publicly traded corporations enacted as part of the Inflation Reduction Act of 2022 (the...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Eversheds Sutherland (US) LLP

Tough Medicine: Litigation lessons from Medtronic

Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more

Miles & Stockbridge P.C.

IRS Issues Additional Guidance on REIT Parking Facility Income

In the recently released Private Letter Ruling 201628020, the IRS considered a situation where affiliated entities owned various properties in an office park; the IRS determined that the entities’ income from leasing space in...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Faegre Drinker Biddle & Reath LLP

New IRS Ruling Benefits Investor-Owned Hospitals

Last month, the Internal Revenue Service (IRS) issued a private letter ruling providing a tax benefit to hospitals that own physician practices. The ruling should be of particular interest to hospitals with physician...more

Akerman LLP

Health Care Reform: Recent Guidance on "Play or Pay" Rules for Applicable Large Employers in 2014

Akerman LLP on

Many important aspects of the Patient Protection and Affordable Care Act ("ACA") will go into effect in 2014, including the implementation of health insurance exchanges, and the requirement for certain employers to offer...more

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