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

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

Health Care Reform – What You Should Know For 2017

This Advisory supplements our previous advisories dated December 2015 (as supplemented in January 2016), October 2014, October 2013, November 2012, November 2011, and October 2010, addressing the requirements of the...more

ACA Tax Reporting Extensions

The IRS has once again extended the deadline for furnishing to employees the applicable tax forms required by the Affordable Care Act (ACA), and will continue to provide employers with penalty relief if they make good-faith...more

IRS Guidance for Implementation of the Section 871(m) Regulations

On December 2, 2016, the Internal Revenue Service (“IRS”) released an advance version of Notice 2016-76 (the “Notice”) and followed through on its promise to provide taxpayers with guidance for complying with final and...more

IRS Updates Conservation Easement Audit Techniques Guide

On November 4, 2016, the IRS updated its Conservation Easement Audit Techniques Guide (CE Audit Guide) for the first time since March 15, 2012. According to the IRS’s introduction on its Audit Techniques Guide website,...more

IRS Phases in Section 871(m) Dividend Equivalent Withholding

On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m). Under the notice, withholding applies only to...more

Personal Planning Strategies - December 2016

2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

Kentucky Court Of Appeals Slashes Punitive Award Against Grant Thornton

A couple of months ago, the Kentucky Court of Appeals in Grant Thornton LLP v. Yung cut a trial court’s award of punitive damages from $80 million to $20 million—reducing the punitive/compensatory ratio to 1:1....more

Captive Insurance - Looming IRS Reporting Deadline

Many businesses have been caught off guard by a recent Internal Revenue Service (IRS) notice that implicates a popular and commonly-used structure to manage risk. The notice employs a broad net and a short deadline, and...more

ACA Tax Reporting Alert

- In Notice 2016-70, the IRS has extended the date on which to furnish copies of the 2016 Form 1095-B or Form 1095-C to employees to MARCH 2, 2017. - The IRS has also extended the "good faith" transition relief from...more

Do As We Say, Not As We Do: Audit Reveals Unencrypted IRS Emails Put Taxpayer Data at Risk

With tax season around the corner, the Internal Revenue Service (IRS) has begun its yearly campaign to educate taxpayers on the importance of protecting their personal information. However, a recent audit of the agency’s...more

Burden of Proof Issues in Gift Tax Matter

A recent case illustrates 3 important burden of proof issues. The general facts of the case involved a merger of a company owned by parents with a company owned by children. The gift tax issue involved the relative value...more

Holiday Horror Series: Part 2- Hectic Holiday Rollovers

With the holidays upon us, we all can relate to how easy it is to mistakenly overlook important things amidst the cheery holiday hustle and bustle: leaving the Christmas ham in the oven a few hours too long, forgetting to...more

Developments in Association Law 2015–2016

The Nonprofit Organizations Practice at Pillsbury has prepared this summary of significant legal and policy developments that have occurred in approximately the past year. All of these developments have potential impacts upon...more

Employers Need To Be Aware Of Potential Pitfalls Of Providing Opt-Out Incentives To Company Health Insurance

In recent proposed regulations, the Internal Revenue Service (IRS) addressed how the Affordable Care Act (ACA) impacts the use of employer opt-out incentives, which are payments to employees who decline an employer’s group...more

The ERISA Litigation Newsletter - November 2016

This month we review a recent Second Circuit decision addressing ERISA plan status as a class member in a securities shareholder class action. As discussed in the article, the decision exposes a potential conflict among the...more

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

IRS Announces Additional Procedure for Accepting Late Retirement Plan Rollovers

The Internal Revenue Code (IRC) provides that distributions from certain retirement arrangements (e.g., qualified retirement plans, individual retirement accounts (IRAs), §403(a) annuity plans, §403(b) tax-sheltered...more

Deadline for Providing Affordable Care Act Statements Has Been Extended

The IRS has extended the deadline by 30 days for providing individuals the 2016 Form 1095-B and Form 1095-C. The new deadline for the individual forms is now March 2, 2017 instead of January 31, 2017....more

Taxes and Divorce

Divorce is tough. Even amicable divorces are financially and emotionally draining. The last thing you need is to have tax problems pop up as a result of divorce proceedings. To avoid such problems here’s a list of some top...more

IRS Proposes Helpful Changes to "Fractions Rule" Tax Regulations

Proposed income tax regulations published by the Internal Revenue Service (IRS) on Nov. 23, 2016, amend the current regulations regarding the application of the "fractions rule" to partnerships that hold debt-financed real...more

IRS Grants Extension of ACA Information Reporting Deadline and Provides Good Faith Standards for 2016 Information Reports

The IRS recently issued Notice 2016-70, which extends certain 2017 deadlines for employer information reporting under the Affordable Care Act (ACA) on health coverage offered to individuals during the 2016 calendar year. The...more

IRS Offers A Short Extension For Certain ACA Reports

The Patient Protection and Affordable Care Act ("ACA") imposes reporting requirements on providers of minimum essential coverage (including insurers and employers that self-insure health benefits) about the coverage provided....more

Employee Benefits Developments - November 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

EMPLOYMENT LAW UPDATE: The IRS Issued an Extension Regarding an Affordable Care Act Reporting Requirement

The IRS issued Notice 2016-70 to provide an extension for employers to file Form 1095-B or Form 1095-C. Form 1095 provides information about health care coverage offered/provided to individuals. The form, originally due on...more

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