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 Issues Final and Temporary Debt-Equity Regulations Under Section 385

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more

IRS Provides Guidance on Reasonable Mortality Charges for Life Insurance Contracts Based on 2017 CSO Tables

On October 19, the Internal Revenue Service (IRS) issued an advance version of Notice 2016-63, addressing the “reasonable mortality charge” requirement under IRC §§ 7702 and 7702A for life insurance contracts based on the...more

The ERISA Litigation Newsletter - October 2016

Editor's Overview - This month, we look at the implications of the two federal district court cases from California that applied the ban on discretionary clauses typically found in ERISA plans to self-insured plans. The...more

Halloween Tax Alert: Beware of the IRS "Wealth Squad"

What’s scarier than zombies, clowns, or vampires? The dreaded Global High-Wealth Industry Group, a/k/a the IRS’s “Wealth Squad.” The Wealth Squad is comprised of highly-specialized examiners and other professionals whose sole...more

Overview of New Section 385 Regulations

The IRS has issued final and temporary regulations under Code Section 385. These provisions, intended to limit earnings stripping, will enhance the IRS' ability to characterize related party ownership arrangements,...more

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

IRS Relief Available to Victims of Hurricane Matthew in North Carolina, South Carolina, Georgia and Florida

Some good news in the wake of Hurricane Matthew: participants in 401(k) and similar employer-sponsored retirement plans who have been adversely affected by Hurricane Matthew may be eligible to use their retirement savings to...more

Be Aware – The Venue for IRS Appeals Conferences Has Changed

Effective October 1, 2016, the Internal Revenue Service (“IRS”) changed its approach to conducting appeals conferences. The changes were likely adopted by the government under the guise of efficiency and cost savings. With...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more

Application of New Debt-Equity Regulations to Securitizations

On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more

Recently Issued Final, Temporary and Proposed Treasury Regulations Regarding the Allocation of Partnership Liabilities and...

On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more

IRS Eases Loan and Hardship Distribution Rules for Hurricane Mathew Victims

In Announcement 2016-39 issued on October 21, 2016, the IRS follows its long-standing practice and eases application of the qualified plan loan and/or hardship rules for those who were impacted by Hurricane Mathew. For...more

IRS Revenue Procedure Confirms IRS Will Respect QTIP Elections When Portability Elections Also Made

The IRS resolved an important issue when it issued Revenue Procedure 2016-49, effective September 27, 2016, clarifying that the IRS would not disregard qualified terminable interest property (QTIP) elections for estates that...more

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Countries at a Glance 2016: United States - Employee Stock Purchase Plans

EMPLOYEE STOCK PURCHASE PLANS - EMPLOYEE STOCK PURCHASE PLANS: EMPLOYMENT - Labor Concerns - A claim for breach of contract could arise where a Plan is amended or discontinued. It is recommended that Plan...more

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

The IRS Voluntary Compliance Program Is Like Your Parents

As a child, you’re usually told by your parents that they just want to hear the truth and that telling the truth is going to carry a far less punishment than if you lie and try to hide whatever bad thing you do. The...more

IRS Issues Final Debt-Equity Regulations

On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more

IRS Clarifies Benefit Coverage Requirements for Employees of Tax-Exempt Disregarded Entities

The Internal Revenue Service (IRS) recently issued General Counsel Memorandum 201634021 (Memorandum), clarifying benefit coverage requirements for employees of a disregarded LLC wholly owned by a single member tax-exempt...more

What You Need to Know About IRS Outstanding Inactive Tax Receivables

Legislation enacted in 12/15 (FAST ACT – Fixing America’s Surface Transportation Act)) required IRS to utilize private debt collection agencies to collect inactive federal tax debts. Starting SPRING 2017, IRS will use private...more

Proposed Regs May Limit US Estate Plan

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

Section 385 Regulations Issued - Not as Harsh as The Proposed Regulations

Earlier this year, the IRS issued proposed regulations on the conversion of purported related party debt to equity. The IRS has now issued temporary and final regulations on the subject....more

Funds Escape Debt-Equity Regulation Net—For Now

Key Points - - The New Regulations do not apply to debt issued by investment partnership funds, including publicly traded partnership funds, or blockers-at least, not now. - The New Regulations can apply to...more

The 5% Solution: IRS Revenue Procedure 2016-42 Provides Relief for the Probability of Exhaustion Test

Charitable Remainder Annuity Trusts (CRATs) can be a very effective charitable planning tool. Choosing to fund a CRAT can remove assets from the estate of the donor, provide a reliable income stream for a family member and...more

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