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

California Updates Conformity to Internal Revenue Code, Provides Large Corporate Understatement Penalty Relief

Governor Jerry Brown signed Assembly Bill 154 on September 30, 2015, updating California’s general conformity to the Internal Revenue Code and providing three new exceptions to the imposition of the Large Corporate...more

Central States Pension Fund Submits Plan for Reducing Benefits

On Sept. 25, 2015, the Central States, Southeast and Southwest Areas Pension Plan (Central States), submitted to the Department of the Treasury a plan for reducing benefits under the Multiemployer Pension Reform Act of 2014...more

CLIENT ALERT: Worker Misclassification

Continuing its focus on combating worker misclassification, the U.S. Department of Labor has awarded nearly $40 million in federal grants to 45 states and territories. The grants are designed to enhance unemployment insurance...more

Tax Alert: Relief for Federal Disaster Areas in South Carolina - State Department of Revenue and Internal Revenue Service Issue...

On October 7, 2015, the Internal Revenue Service (IRS) issued SC-2015-71 to grant relief to taxpayers located in federal disaster areas of South Carolina....more

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing. “I’m mad as Hell, and, frankly, I’m not going to take it anymore.” — Paraphrase of concerned citizen and...more

New Treasury Regulations Make it Easier to Issue Tack-On Bonds or Loans

On September 12, 2012, the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) which make it easier to issue fungible tack-on debt instruments in situations where either the original debt...more

Worthless Debt Deduction – A Cautionary Tale

For partnership, individuals and other types of taxpayers that are not in the business of making loans, the main avenue for tax relief when a loan goes bad is Section 166 – the bad debt deduction. In order to claim this...more

IRS Proposes New Rules for Substantiating Charitable Contribution Deductions: What Every Charity Needs to Know

Anyone who has ever given to a charity is familiar with the contribution receipt: it thanks the donor for the contribution, indicates the dollar amount of the gift and states that the charity did not provide any goods or...more

Final Forms and Instructions for ACA Information Reporting Released

The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”). The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage. The...more

Best in Law: Tax Ruling Confirms Protocol on Job-Related Judgments

The California Court of Appeal recently confirmed that employment-related settlements or judgments are wages from which employers must withhold payroll taxes. In Cifuentes v. Costco Wholesale Corp., Cifuentes...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 12 of 24): Deconstructing Form 1095-C, Parts II...

This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more

Do Seasonal Workers “Count” for Forms 1094-C and 1095-C?

We were asked that recently, proving that there is such a thing as a wrong question. Let’s break it down. The same person may be both a “seasonal worker” and a “seasonal employee,” but those terms are used to discuss separate...more

Wealth Management Update - October 2015

October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

New Projects and Updates From the IRS Employee Plans Compliance Unit

The IRS Employee Plans Compliance Unit (EPCU) recently announced two new projects and updated two others. In each case EPCU is using compliance checks as a tool to increase IRS enforcement presence and ensure compliance....more

Don’t Burst My Bubble! IRS Provides Clarity for F Reorganizations

Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more

Now’s the Time to Review Compensation Arrangements Relating to Unvested Rights

Correction of Errors before Year End Could Avoid Costly 409A Penalties - Sometimes overlooked is the fact that many employment, severance and change-of-control agreements are subject to U.S. Internal Revenue Code...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Perspectives - September/October 2015

In a decision in which no opinion commanded a majority, the Ohio Supreme Court sided with a private entity — a charter school operator — in a dispute over the ownership of personal property purchased by the operator with...more

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010...more

Employers Will Begin Receiving Premium Subsidy Award Notices From The Health Care Exchange in 2016

Beginning in 2016, the Centers for Medicare & Medicaid Services (CMS) will begin its process of verifying the eligibility of recipients who receive the Affordable Care Act’s (ACA) advanced premium tax credit to help purchase...more

IRS Publishes Final Regulations for Equivalency Determinations

Take note of these practical concerns for private foundations making grants to foreign organizations. On September 25, the Internal Revenue Service (IRS) published final regulations for private foundations making good...more

It's Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the...more

Hot Topics: Worker Classification Issues

Worker classification issues are popping up in the news a lot again. This is because the National Labor Relations Board (NLRB) is taking a more aggressive view on joint-employer standards under the National Labor Relations...more

IRS Provides Guidance on Fund of Funds

On September 15, the Internal Revenue Service published final regulations revising examples related to the application of the controlled group rules to regulated investment companies (RIC) and how the controlled group rules...more

Employee vs. Independent Contractor — A Decision Not To Be Taken Lightly

Most employers know that workers may be either employees or independent contractors. What many employers do not know is that misclassifying a worker into the wrong category could have significant financial consequences....more

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