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Internal Revenue Service › Check the Box Rules

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.  
Foster Garvey PC

A Narrow Aspect of the Check-the-Box Regulations that Deserves Some Press – Changing an Entity’s Tax Classification From That of a...

Foster Garvey PC on

More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

Foster Garvey PC on

More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Bilzin Sumberg

IRS Provides More Guidance on “Relevance” and Foreign Entities Making “Check-the-Box Elections”

Bilzin Sumberg on

In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context.  More specifically, the guidance addressed issues...more

Bilzin Sumberg

Navigating Pandora’s Hallelujah Mountains: Civil Law Foundations, U.S. Tax Classification and Related Penalty Issues

Bilzin Sumberg on

One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more

Bilzin Sumberg

It's All Relevant: Recent IRS Guidance Affecting Pre-Immigration Planning

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The IRS recently issued general legal guidance illustrating the application of the often misunderstood relevance rules for foreign entities in various settings....more

The Volkov Law Group

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

The Volkov Law Group on

When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more

Bilzin Sumberg

Check-the-Box Elections: Relevance in the International Context

Bilzin Sumberg on

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

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