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Internal Revenue Service Income Taxes

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.  
Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

Rivkin Radler LLP on

You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Troutman Pepper

FERC Chief Accountant Proposes to Modify Transferability of Income Tax Credits

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On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more

Obermayer Rebmann Maxwell & Hippel LLP

The Impact of a Divorce on Taxes

The post-Labor Day surge in family law cases comes with many questions, including concerns about upcoming holidays, and whether a divorce will be finalized by year-end. For some, the imminent tax extension deadline for...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman David Schweikert, R-AZ

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy and political debates in Congress. In this episode of “The Cloakroom with...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – August 30, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – August 23, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024. August 19, 2024: The IRS released Internal Revenue Bulletin...more

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

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As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

Lowenstein Sandler LLP

Puttin’ on Your Top Hat: How to Effectively Structure a Deferred Compensation Plan as a “Top Hat” Plan

Lowenstein Sandler LLP on

“Top hat plans” —non-qualified deferred compensation plans that can be exempt from most of the requirements of Employee Retirement Income Security Act of 1974 or ERISA—can be a useful tool for employers looking to provide...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Purchasing U.S. Real Estate by Non-U.S. Persons

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Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more

McDermott Will & Emery

Family Office Symposium 2024 | Key Takeaways

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McDermott’s Family Office Symposium 2024 gathered more than 275 family office executives to explore creative solutions to navigate complexity and gain fresh perspectives on the challenges they face. Over two days,...more

McDermott Will & Emery

Weekly IRS Roundup August 5 – August 9, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more

Miller & Martin PLLC

The 6th Circuit Splits the Pie in Parker v. Battle Creek Pizza FLSA Litigation

Miller & Martin PLLC on

Classic Domino’s ads warned to “Avoid the Noid.” Recently, the plaintiff’s bar has been the Noid for pizzerias and similar restaurants. These employers typically pay delivery drivers minimum wage, minus a tip credit, and...more

Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 2, 2024

This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Gerald Nowotny - Law Office of Gerald R....

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Congressman Brendan Boyle, D-PA

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

Bradley Arant Boult Cummings LLP

How New IRS Actions Affect Your ERC Claim

With the passage of the 2020 CARES Act, Congress created the Employee Retention Credit (ERC) for eligible employers whose operations were impacted by the COVID-19 pandemic. The IRS, however, stopped processing new ERC claims...more

McDermott Will & Emery

Weekly IRS Roundup July 22 – July 26, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Pre-immigration Planning for Moving to the United States

BakerHostetler on

Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more

McDermott Will & Emery

Weekly IRS Roundup July 15 – July 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15, 2024 – July 19, 2024. ...more

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Fox Rothschild LLP

Partnership Interest Sale Inventory Gain is Not U.S. Source Income

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On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more

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