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Internal Revenue Service American Taxpayer Relief Act

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.  
Alston & Bird

Section 721(c) Partnership Regulations Arrive Just in Time

Alston & Bird on

On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Proskauer Rose LLP

Wealth Management Update - August 2015

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

Holland & Knight LLP

Regulatory Update: Final Regulations on Portability of the DSUE

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Portability of the deceased spousal unused exclusion (DSUE) amount between spouses was first introduced by Congress in December 2010, applicable to estates of married decedents dying on or after Jan. 1, 2011. Although...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Opportunities For In-Plan Roth Rollovers

In furtherance of Section 902 of the American Taxpayer Relief Act of 2012 (ATRA), the Internal Revenue Service (IRS) recently issued Notice 2013-74 updating prior IRS guidance regarding so-called “in-plan” Roth conversions...more

Morgan Lewis

IRS Issues Notice on Expanded In-Plan Roth Conversion Option

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Guidance confirms that plan sponsors have flexibility in designing and implementing a feature that allows participants to convert vested pre-tax balances to after-tax Roth balances....more

K&L Gates LLP

IRS Notice 2013-60 Clarifies Rules on Beginning of Construction

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On September 20, 2013, the U.S. Department of the Treasury (“Treasury”) released Notice 2013-60, which clarifies in important ways the eligibility rules applicable to the investment tax credit (“ITC”) and production tax...more

Stoel Rives LLP

IRS Likely to Supplement "Beginning Construction" Guidance

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As most of you are aware, Congress in the "American Taxpayer Relief Act of 2012" eliminated the "placed in service" deadline for purposes of the renewable energy tax credits. In its place, Congress required for purposes of...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Supreme Court DOMA Decision—Part II: Wage Overstatements and Tax Refunds

In part one of this two-part series, “Supreme Court DOMA Decision — Part I: Fringe Benefits and Other Tax Implications,” I reviewed the fringe benefit and tax implications of the United States v. Windsor decision....more

Shumaker, Loop & Kendrick, LLP

Tax Planning for the “New Normal”

Effective January 1, 2013, the American Taxpayer Relief Act of 2012 (“ATRA”) was enacted into law, finally settling years of debate over the fate of the Bush era tax cuts. On the same day, the 3.8% Medicare Tax on net...more

Morgan Lewis

IRS Releases “Start Construction” Guidance for Renewable Energy Facilities

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Long-awaited guidance regarding eligibility for production or investment tax credits largely tracks guidance under the Section 1603 cash grant program....more

Stinson LLP

Energy Alert: IRS Identifies Two "Begun Construction" Standards To Qualify For Two Tax Credit Opportunities

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The renewable electricity production tax credit and the energy investment tax credit currently offer taxpayers a tax credit for energy produced from qualified facilities. For the PTC, the tax credit covers a ten-year period....more

Foley Hoag LLP - Energy & Climate Counsel

IRS Issues “Beginning Construction” Guidance for PTC and ITC

On April 15, 2013, the Internal Revenue Service issued anticipated guidance defining the new “beginning construction” milestone for Production Tax Credit and Investment Tax Credit eligible energy facilities....more

Proskauer Rose LLP

Wealth Management Update - February 2013

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In This Issue: - February Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - IRS Issues Revenue Procedure 2013-15 - Private Letter Ruling...more

Davis Wright Tremaine LLP

Production Tax Credit Update: IRS Plans to Release Guidance on Applying the “Begun Construction” Test

According to Tax Notes Today, the IRS discussed its plans to release guidance on applying the “begun construction” test for the production tax credit (“PTC”) at the American Bar Association Section of Taxation meeting in...more

King & Spalding

American Taxpayer Relief Act of 2012: Expanded Roth Conversions and Other Benefit and Retirement Related Provisions

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On January 2 , 2013, President Obama signed the American Taxpayer Relief Act of 2012 (H.R. 8) (the “Relief Act”) into law. While the principal intention of the Relief Act was to avert the key elements of the “fiscal cliff” by...more

Morrison & Foerster LLP

Tax Talk -- Volume 5, No. 4 -- January 2013

In This Issue: Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more

Troutman Pepper

IRS Provides Administrative Guidance On Excludable Transportation Benefit Limits, Retroactively Increased As Of January 1, 2012

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On January 16, 2013, the Internal Revenue Service (IRS) issued Notice 2013-8 providing a special administrative procedure for employers with respect to 2012 transit benefits. Under Section 132(f) of the Internal Revenue Code...more

McDermott Will & Emery

Employers Can Obtain Refund for Excess FICA Tax Paid as Result of Increased Excludable Limit for Transit Benefits

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On January 11, 2013, the Internal Revenue Service published Notice 2013-8 providing a special administrative procedure for employers with respect to 2012 transit pass benefits. The American Taxpayer Relief Act retroactively...more

Snell & Wilmer

Fiscal Cliff Legislation Expands In-Plan Roth Conversions for Qualified Plans

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On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”), more commonly known as the fiscal cliff legislation. Among other things, the Act amended the tax code to remove some of...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Guidance to Implement Retroactive Increase in 2012 Mass Transit Benefit Limits—January 31 Deadline

On January 16 the Internal Revenue Service (IRS) issued guidance on the application of the retroactive increase in excludible transit benefits, as enacted under the American Taxpayer Relief Act of 2012 (ATRA). IRS Notice...more

Morrison & Foerster LLP

New Tax Act Provides Long-Awaited Clarity and Certainty on Estate, Gift and Generation-Skipping Transfer Taxes, and Income Tax...

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (ATRA), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama on January 2,...more

Baker Donelson

Congress Extends Exclusion for Investors in Qualified Small Businesses

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Among the taxpayer-favorable aspects of the American Taxpayer Relief Act of 2012 (Act), the 100 percent exclusion from gross income of gain on the sale of Qualified Small Business Stock (QSBS), provided for in section 1202 of...more

McDermott Will & Emery

New Law Expands “In-Plan” Roth 401(k) Conversions

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The American Taxpayer Relief Act of 2012 (the "fiscal cliff" bill) allows employers to amend 401(k), 403(b) and governmental 457(b) plans to permit participants to convert pre-tax account balances to Roth account balances. ...more

Manatt, Phelps & Phillips, LLP

New Tax Act's Impact on Planning for Charitable Donations

New Year's Day brought new tax legislation passed by Congress, called the American Taxpayer Relief Act of 2012 (the "Act"), which President Obama has signed into law. The Act has made some important changes to the tax law...more

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