News & Analysis as of

Internal Revenue Service Protecting Americans from Tax Hikes (PATH) 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.  
Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

Paul Hastings LLP on

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

Eversheds Sutherland (US) LLP

Choose your own adventure: IRS releases Rev. Proc. 2020-25 providing taxpayers with options to utilize the CARES Act’s QIP...

On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more

Morgan Lewis

Nonemployee Compensation Reportable on Revived Form 1099-NEC for 2020 Payments

Morgan Lewis on

The Internal Revenue Service has revived Form 1099-NEC to eliminate confusion about complying with new filing deadlines aimed at combatting fraud. ...more

Nossaman LLP

IRS Issues Final Rules for Notice of Intent to Operate as 501(c)(4) Social Welfare Organization

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The IRS on July 23 issued final regulations (“Final Rules”) implementing the Internal Revenue Code section 506 requirement that an entity notify the IRS of its intent to operate as a Code section 501(c)(4) social welfare...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, February 2019 #3

MEET THE MEMBERS - Now that everyone is familiar with the new House Ways and Means Committee members, it’s time to meet the newbies in the upper chamber’s tax writing committee: the Senate Finance Committee. Joining the...more

Bracewell LLP

Bracewell Tax Report - October 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Bowditch & Dewey

Bonus Depreciation: What You Need to Know for Your Business

Bowditch & Dewey on

Since 2002, bonus depreciation under the Job Creation and Worker Assistance Act has been allowed in some form. Bonus depreciation allows for more current expensing for eligible property than allowed under the current...more

Foley & Lardner LLP

BREAKING NEWS: Congress Sends Tax Cuts and Jobs Act to President Trump’s Desk for Signing

Foley & Lardner LLP on

The Tax Cuts and Jobs Act (TCJA) has been passed by both houses of Congress and is now set to be signed into law by President Trump. The vote was 224-201 in the House with all the Democrats joined by twelve Republicans voting...more

Akin Gump Strauss Hauer & Feld LLP

Considerations for Asian Fund Managers under the U.S. New Partnership Audit Regime

The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more

Foley & Lardner LLP

The GOP’s Tax Cuts and Jobs Act Includes Changes Impacting the Renewable Energy Industry

Foley & Lardner LLP on

On November 3rd, House Ways and Means Committee Chairman Kevin Brady (R. Tex.) released the “chairman’s mark” to H.R. 1, the “Tax Cuts and Jobs Act” (TCJA). The TCJA represents the most extensive rewrite of the Internal...more

Morrison & Foerster LLP

Treasury Report Proposes Substantial Revisions to Controversial Tax Regulations

Morrison & Foerster LLP on

Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more

Proskauer - Tax Talks

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

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The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

Lowndes

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

Lowndes on

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

McDermott Will & Emery

IRS Issues Additional Guidance on Beginning of Construction Rules for Renewable Projects

McDermott Will & Emery on

On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been...more

Mayer Brown

IRS Extends Continuity Safe Harbor Until December 31, 2018

Mayer Brown on

On December 15, 2016, the US Internal Revenue Service (the “IRS”) released Notice 2017-4 (the “Notice”), which updates previous IRS “start of construction” guidance by extending the Continuity Safe Harbor to December 31,...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

McDermott Will & Emery

Payroll Get Ready — Employers Face New January 31st Filing Deadline for W-2 and 1099-MISC Forms

McDermott Will & Emery on

In Depth - Beginning with W-2 forms filed with respect to 2016 wages, a new law requires employers to file the government copy by January 31, 2017, for both paper and electronic copies. The accelerated deadline also...more

McGuireWoods LLP

Tax-Exempt Organizations Update: Selected Developments From Washington

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Although comprehensive tax reform in 2016 is unlikely in the midst of an election year, so far in 2016, parties on all sides have proposed specific changes to the rules applicable to exempt organizations. Lawmakers in...more

Holland & Knight LLP

IRS to Invalidate Unused ITINs Unless Renewed

Holland & Knight LLP on

The Internal Revenue Service (IRS) is requiring individuals with inactive or old individual taxpayer identification numbers (ITINs) to renew their ITINs. The renewals impact individuals who received ITINs prior to 2013. The...more

Proskauer - Not for Profit/Exempt...

New Electronic Form 8976 to Alert IRS About Section 501(c)(4) Status; 1023-EZ Application Reduced to $275

The Protecting Americans from Tax Hikes (“PATH”) Act of 2015, enacted in December 2015, requires organizations to notify the IRS if they desire to operate under Section 501(c)(4) of the Internal Revenue Code (“Code”). (Only...more

Clark Hill PLC

IRS Announces 501(c)(4) Notification Process

Clark Hill PLC on

The Internal Revenue Service ("IRS") has issued temporary regulations explaining how organizations exempt under Section 501(c)(4) of the Internal Revenue Code must provide notice to the Service within 60 days of formation. ...more

Patterson Belknap Webb & Tyler LLP

PATH Act 501(c)(4) Matters Update #2: Notification Requirement Clarified; Temporary Regulations and Notification Form Issued

As specified in Notice 2016-09 (discussed in our recent blog post on the PATH Act), the IRS has issued temporary regulations describing new notification procedures and a notification form for certain (current and prospective)...more

Perkins Coie

New IRS Notification Requirement for Certain 501(c)(4)s

Perkins Coie on

The IRS published temporary proposed regulations on July 12, 2016 that will impact all 501(c)(4) social welfare organizations formed after July 8, 2016. The proposed regulations will also impact many existing 501(c)(4)...more

Polsinelli

Small Business Investors Can Save Big with New IRS Code Amendments

Polsinelli on

Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Corrects Effective Date of Recently Issued Built-in Gain Regulations"

The Internal Revenue Service (IRS) and Treasury Department today issued a much-welcomed technical correction to the effective date of the recently issued “built-in gain” regulations regarding real estate investment trust...more

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