News & Analysis as of

Internal Revenue Service Disclosure

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.  
Jackson Lewis P.C.

Health Plan Hygiene Part 1: A Spoonful of Sugar Helps the Medicine Go Down

Jackson Lewis P.C. on

During the next several weeks, we will publish a series of articles that dive deeply into “health plan hygiene” relating to health and welfare benefit plan fiduciary issues and how employers can protect themselves in this...more

McGlinchey Stafford

TILA Disclosure Requirements Limited by New York District Court

McGlinchey Stafford on

On June 5, 2024, the United States District Court for the Southern District of New York issued a decision adopting in its entirety the May 13, 2024, Report and Recommendation regarding the Truth in Lending Act (TILA). The...more

ArentFox Schiff

IRS Data Leak Hits Home: Actions for Taxpayers in the Wake of the Littlejohn IRS Data Breach

ArentFox Schiff on

The Internal Revenue Service (IRS) has begun the process of informing over 70,000 taxpayers that their confidential tax information was leaked in a widespread breach by a former IRS contractor. Those impacted should take...more

Allen Barron, Inc.

Willful versus Non-Willful Conduct in the Eyes of the IRS

Allen Barron, Inc. on

What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more

ArentFox Schiff

What Private Companies Need To Consider in 2024: Top 10 Legal Issues

ArentFox Schiff on

Private companies and their owners face ever-evolving challenges as the market sees new regulations, new deal trends, and new risks in 2024. Below are 10 issues that the owners and leaders of privately held companies should...more

Rivkin Radler LLP

5 Factors to Help Smooth a Syndication Deal

Rivkin Radler LLP on

You found the right site. You completed the due diligence and are negotiating the purchase and sale agreement. Now you must raise the equity. You have multiple sources, each with differing financial issues from tax to return...more

Faegre Drinker Biddle & Reath LLP

Discretionary Management of IRAs: Conflicts and Prohibited Transactions

Both the Internal Revenue Code (Code) and the Employee Retirement Income Security Act of 1974 (ERISA) include prohibited transaction provisions that literally prohibit certain transactions (unless exempted by statute or by a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Revenue Procedure 2022-39 Continues Qualified Amended Return Treatment for Audit Disclosures, Adds Large Partnership

On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more

McDermott Will & Emery

IRS Issues New Procedures for Large Corporate Audit Disclosures

McDermott Will & Emery on

For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal Revenue Service (IRS) of adjustments...more

McDermott Will & Emery

The IRS Can Share Tax Information with Foreign Governments

McDermott Will & Emery on

The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share your tax information with foreign...more

McDermott Will & Emery

IRS to Update Schedule UTP to Require Additional Transparency

McDermott Will & Emery on

On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more

McDermott Will & Emery

IRS Proposes New Process for Post-Filing Disclosures to Replace Revenue Procedure 94-69

For many years, the Internal Revenue Service (IRS) has provided large corporate taxpayers who are under continuous audit to make affirmative disclosures at the start of an audit so they have an opportunity to disclose tax...more

Morrison & Foerster LLP

International Tax Disputes Insights Newsletter (Spring 2021)

Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more

Foley & Lardner LLP

Disclosure of 1023 and 990 Forms for Nonprofits

Foley & Lardner LLP on

Tax-exempt organizations (including private foundations, which are subject to special additional disclosures) are subject to certain public disclosure rules. These rules require that the organization make its exemption...more

Wiley Rein LLP

Political Privacy Update: Solicitor General Supports Certiorari in California Donor Privacy Cases

Wiley Rein LLP on

Privacy in Focus has been tracking three petitions for certiorari pending in the U.S. Supreme Court in cases challenging California’s mandate for nonprofit organizations to disclose their donors to the state Attorney General...more

McCarter & English, LLP

Disclosure Industry Working Group Encourages Timely Covid-19 Disclosures

The Disclosure Industry Working Group reminds issuers that applicable filing deadlines have not been extended by either the U.S. Securities and Exchange Commission (SEC) or the Internal Revenue Service (IRS), and encourages...more

Ballard Spahr LLP

Key Developments in the Prosecutions for Leaks by Government Personnel of SARs Related to Michael Cohen, Paul Manafort, Richard...

Ballard Spahr LLP on

Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more

Ballard Spahr LLP

IRS Issues Clarification Regarding Taxpayer First Act Disclosure of Information Provision

Ballard Spahr LLP on

The Taxpayer First Act adopted in the summer of 2019 includes the following provision that has an effective date of December 28, 2019...more

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