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 releases updated safe harbors for management contracts in tax-exempt bond-financed projects

On August 22, 2016, the Internal Revenue Service released Revenue Procedure 2016-44. The purpose of this revenue procedure is to provide revised and broader “safe harbors” under which certain private management contracts will...more

IRS Loosens Restrictions on Safe Harbors for Management Contracts for Bond-Financed Property

The Internal Revenue Service, in Revenue Procedure 2016-44, has loosened the restrictions on safe harbors for management contracts entered into by governmental issuers of tax-exempt bonds in connection with facilities...more

Treasury Announces 2016-2017 Regulatory Agenda for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. ..On August 15, 2016, the U.S. Department of the Treasury and the Internal Revenue Service...more

Proposed 2704 Regulations Attack Valuation Discounts

The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...more

IRS Simplifies Rules for Correcting Failed Rollover

On August 24, 2016 the IRS published Revenue Procedure 2016-47, which simplifies the steps for correcting a missed rollover from a qualified plan or IRA to another qualified plan or IRA. Amounts distributed from a qualified...more

New IRS Management Guidance is Flexible, Furthers P3s

State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...more

New IRS Self-Certification Procedure Eases Complexity of Obtaining Waiver of 60-Day Time Limit on Rollovers of IRA and Employer...

Action Item: On August 24, 2016, the Internal Revenue Service (“IRS”) issued new guidance that allows individuals who inadvertently fail to complete the rollover of a distribution from an individual retirement account (“IRA”)...more

Proposed Rules Would Limit Valuation Discounts for Family Controlled Entities

On August 2, 2016, the Internal Revenue Service proposed regulations that would severely limit valuation discounts for lack of marketability and lack of control that taxpayers have historically applied for federal gift,...more

IRS Publishes New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more

Section 501(c)(4) Organizations Subject to IRS Notice Requirement

Nonprofit entities that intend to operate as tax-exempt organizations described in section 501(c)(4) of the Internal Revenue Code (Code) are subject to new reporting requirements with the IRS. Specifically, newly-enacted...more

IRS Relaxes Restrictions on Management Contracts for Bond-Financed Facilities

The IRS on August 22, 2016 released long-anticipated Revenue Procedure 2016-44 (Rev. Proc. 2016-44), which substantially increases flexibility in, and provides a less formulaic approach to, the ability of a tax-exempt bond...more

IRS Proposes Rules That Would Dramatically Reduce Valuation Discounts in Family Business Succession Planning

Business Owners May Have Little Time to Act Before Rules Are Finalized - The valuation of a family member's interest in a family business has a major impact on the success or failure of a transfer of such interest to...more

Client Alert: New Safe Harbors for Management Contracts of Tax-Exempt Financed Facilities

The Internal Revenue Service on August 22, 2016 released Revenue Procedure 2016-44 which revises the safe harbor guidelines for management contracts of service providers for tax-exempt financed facilities, under which the...more

Do You Know About the 4 Scenarios in the IRS Collection Process?

The IRS collection process begins when IRS does not receive full and timely payments from a taxpayer after it issues a collection notice. Based on the information in the taxpayer’s 1040 tax return, if the taxpayer does not...more

Estate Tax Changes Past, Present and Future

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

Blog: Court Gives Energy Transfer the Right to Walk Based on its Counsel’s Inability to Deliver the Required Tax Opinion

In a rare decision involving unusual facts, the Delaware Court of Chancery held that a buyer (Energy Transfer Equity, L.P.) had the right to terminate a signed merger agreement with its target (The Williams Companies, Inc.)...more

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

IRS Issues New Management Contract Safe Harbors

Almost 20 years ago, the IRS released Rev. Proc. 97-13, outlining multiple safe harbors under which a management contract would not result in private business use of bond-financed proceeds. These safe harbors, while helpful,...more

IRS Proposes Regulations That Will Eliminate Most Valuation Discounts on Family-Owned Entities

On August 2, 2016, the IRS issued proposed regulations that would eliminate or limit the use of certain valuation discounts regularly applied when valuing interests in family-owned entities for gift and estate tax...more

IRS Proposes New Regulations That Will Significantly Limit the Use of Valuation Discounts on Transfers of Interests in Closely...

The proposed regulations disregard restrictions that have been used by valuation experts and acknowledged by the courts to reduce valuations. If you are an owner of a closely held entity, recently proposed Treasury...more

Consider Your Options for Charitable Giving - Trusts and Estates Update Volume 2016, Issue 1

There are many charitable giving options that are available to fit a donor’s specific goals. You do not have to be Bill Gates or Warren Buffett to make a difference in the world now and after you are gone. Most of our...more

2016 Draft Instructions For 1094-B and 1095-B

Last week, the IRS released draft 2016 instructions for the 1094-B and 1095-B (the “B” Forms). The release of the draft instructions is just weeks after the IRS released the draft instructions for the 1094-C and 1095-C...more

Proposed Section 2704 Regulations

On August 2, 2016, the Treasury Department released proposed regulations amending and expanding upon the current regulations to Internal Revenue Code Section 2704. The proposed regulations, if adopted, would affect the...more

IRS Guidance on Section 457: What Non-Profit and Governmental Employers Need to Know (Part 2)

We're back with the second installment in our series on the IRS's Section 457 proposed rules. The first alert covered Section 457(f) basics and discussed the meaning of "deferred" compensation....more

UPDATE: List of Georgia Hospitals Eligible for Contributions Nears Completion

On April 24, 2016, Georgia Governor Nathan Deal signed into law S.B. 258, a bill permitting individuals and companies to receive state tax credits for contributions to certain rural Georgia hospitals. As AGG previously...more

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