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.  

Tax court finds self-employment tax for active LLC member

by Thompson Coburn LLP on

Self-employment (SE) tax is one of the driving forces when a tax advisor recommends what type of entity to use for one’s business. My previous post, “Tax court finds no self-employment tax for passive LLC member,” described...more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

by Foodman CPAs & Advisors on

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

IRS Issues New Rules for Management Contracts involving Tax-Exempt Financed Facilities

by Miller Canfield on

The Internal Revenue Service (IRS) issued Revenue Procedure 2017-13 (Rev. Proc. 2017-13) on Jan. 17, 2017. The procedure provides more flexible, modern rules for structuring management contracts involving tax-exempt financed...more

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Collection of Funds in Individual Retirement Accounts: Are They Really Exempt?

by Clark Hill PLC on

This article explores the assumption that IRAs are fully exempt from attachment by judgment creditors. Recently, Clark Hill argued that a judgment debtor's use of IRA funds for purposes that were not intended by Illinois...more

Filing Your Own Return

by Moskowitz LLP on

In our last post, we reviewed the main advantages and disadvantages of joint tax returns for married couples. This post will focus on when a married couple should consider filing separately, and special considerations if they...more

Podcast - Shrink the Section 457A Tax on Hedge Fund Management and Incentive Fees and Expand Your Impact

by Ropes & Gray LLP on

In a recently released Ropes & Gray podcast, asset management partner Isabel Dische, tax partner Brett Robbins, and private client partner Cameron Casey discuss the effect of Section 457A on pre-2009 management and incentive...more

IRS Provides Guidance to Employers Using Payroll Service Providers

by Nexsen Pruet, PLLC on

These days, the majority of mid-to-large employers use payroll service providers for ease of payroll recordkeeping and administration. These third party providers help ease the burden of calculating taxes and withholding,...more

The Joint Tax Return

by Moskowitz LLP on

IRS data indicates that over 95% of married couples file jointly – and for most, but not all, couples this makes good economic sense. In this two-part series, we will discuss the advantages and disadvantages of filing joint...more

Update on Transaction Costs - 'Origin of the Claim' Analysis Will Decide Tax Allocations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

While the Internal Revenue Service (IRS) has continued to issue guidance addressing the ability to deduct transaction costs, the doctrine of "Origin of the Claim" (OOC) developed over 50-plus years of case law is still the...more

Forgiveness of Debt Can Prove Unforgiving, But a New Federal Court Decision Gives Cause for Optimism

by Hinshaw & Culbertson LLP on

A federal court in New Jersey recently dismissed a putative class action filed under the Fair Debt Collection Practices Act, which had argued that it was deceptive conduct for a debt collector to inform the debtor that...more

A Step in the Right Direction: IRS Rules on North-South Spinoffs

The Internal Revenue Service (IRS) recently released guidance on certain “north-south” spinoff transactions. Generally, a “north-south” transaction consists of a transfer of property from a shareholder to a corporation close...more

The Time is Right to Contact Recordkeepers About Hardship Substantiation

If your 401(k) plan recordkeeper has not talked to your company lately about hardship distributions, it may be time to reach out to the recordkeeper. The short story is that the IRS recently issued an internal memorandum...more

Guidance For North-South Spinoffs

by Farrell Fritz, P.C. on

The IRS continues to issue guidance in the much debated area of corporate spinoffs. A recently published ruling examined the federal income tax treatment of the two steps that comprise a so-called “north-south” transaction.”...more

Court Denies Motion For Preliminary Injunction Prohibiting The IRS From Enforcing The Micro-Captive Disclosure Requirements In...

by Fox Rothschild LLP on

On November 1, 2016, the IRS issued Notice 2016-66 imposing new reporting requirements on micro-captives and their material advisors (see prior post describing the Notice). On March 27, 2017, CIC Services, LLC and Ryan, LLC...more

IRS Budget Cuts Continue to Worsen

by Garvey Schubert Barer on

As I have reported in my previous blog posts, the IRS continues to get hit with severe budget cuts. The result is not pretty: (i) tax collections are on the decline; (ii) the Tax Gap is growing; (iii) taxpayer non-compliance...more

2018 Health Savings Account Figures Released

by Tucker Arensberg, P.C. on

Earlier this month, the IRS released the 2018 inflation-adjusted figures for contributions to Health Savings Accounts (HSAs). As a reminder, HSAs are individual accounts that may be used for reimbursement of certain health...more

Key Tax Changes in the American Health Care Act

by Dickinson Wright on

The American Health Care Act ("AHCA"), passed by the House of Representatives on May 4, 2017, repeals many of the taxes added by the Affordable Care Act ("ACA") and makes changes to other tax rules. Some of the notable...more

Insurance Proceeds Payable To Tenant Diverted To Pay For Property Owner's Back Taxes

The Third Circuit Court of Appeals sitting in Pennsylvania recently issued a precedential decision that interpreted the definition of a “named insured” under a tax delinquency statute to encompass tenants of a property even...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

IRS Criminal Investigation Division Announces New Priorities

by Blank Rome LLP on

At the ABA Section of Taxation’s 2017 May Meeting, Erick Martinez, the IRS Criminal Investigation Division’s Director of Field Operations – Northern Area, provided insight into the Division’s current priorities and...more

Members Of Congress Question IRS’s Digital Currency Strategy Including “John Doe” Summons To Coinbase

by Fox Rothschild LLP on

Three influential members of Congress have questioned the Internal Revenue Service’s strategy for addressing the tax treatment of digital or virtual currencies, such as Bitcoin, and its efforts to uncover the identities of...more

Challenge and Counter-Proposal

by Moskowitz LLP on

In Part I, we outlined the scope of the November 2016 summons served on Coinbase to identify its users and their transaction activity and the IRS’ justification for requesting this data under 26 U.S. Code § 7602. Section 7602...more

More on Transfer Tax Issues Post Windsor and the Legalization of Same-Sex Marriage

by Bryan Cave on

In a recent Notice, the Internal Revenue Service set forth some administrative procedures helping taxpayers recalculate gift and generation-skipping transfer tax exemption with respect to gifts and bequests made to or for the...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

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