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Internal Revenue Service Treasury

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

Puerto Rico - Qualified Retirement Plans: 2020 Year-End Amendments Deadline Coming Soon

With the fourth quarter of 2020 upon us, it is time to evaluate the year-end amendments that may be needed for retirement plans that are tax-qualified in Puerto Rico. Unlike the Internal Revenue Service, which each year...more

A&O Shearman

Temporary Regulations Provide NOL Carryback Waiver Relief to Consolidated Groups

A&O Shearman on

On July 2, 2020, the U.S. Internal Revenue Service (the “IRS”) and the U.S. Treasury Department (“Treasury”) promulgated temporary regulations under section 1502 of the Internal Revenue Code of 1986, as amended (T.D. 9900)...more

Farrell Fritz, P.C.

Real Estate, CARES And Taxes: The Response To COVID-19

Farrell Fritz, P.C. on

The Coronavirus Aid, Relief and Economic Security (“CARES”) Act became law[i] on March 27, 2020. Almost immediately, “small” businesses from every industry – including real estate – began the process of determining whether...more

Littler

Puerto Rico Treasury Again Extends Deadlines to Request Federal Employee Retention Benefit After Hurricanes Irma And María

Littler on

On May 17, 2019, the Puerto Rico Department of the Treasury (“PR Treasury”) issued Internal Revenue Informative Bulletin No. 19-07, granting an additional extension until June 30, 2019 for employers to request the Federal...more

Dickinson Wright

New IRS Audit Rules: Is Your Healthcare LLC Ready?

Dickinson Wright on

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, contains significant changes to the way the IRS will audit partnerships beginning in 2018. These changes will also have far ranging...more

Foster Garvey PC

The New Partnership Audit Regime Will Be Here Soon – Are You Ready?

Foster Garvey PC on

On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

McDermott Will & Emery

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

McDermott Will & Emery on

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

Orrick, Herrington & Sutcliffe LLP

IRS Announces Intent to Tax Transfers to Partnerships

On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more

Snell & Wilmer

The IRS Takes Aim at De-Risking of Defined Benefit Plans

Snell & Wilmer on

Many defined benefit plan sponsors are looking for ways to reduce the on-going liability and the volatility of the annually required contributions to their defined benefit plans, which is sometimes referred to as...more

Dechert LLP

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

Dechert LLP on

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Imposes Toll Charge on Some Transfers of Assets by U.S. Taxpayers to Partnerships with Their Foreign Affiliates

On August 6, 2015, the Treasury and the IRS issued Notice 2015-54, which implements a Clinton-era tax provision intended to prevent U.S. taxpayers from using the partnership provisions of the Code to shift built-in gain on...more

McGuireWoods LLP

The “Cadillac Tax”: A Tankful of Issues: McGuireWoods Healthcare Reform Guide: Installment No. 52

McGuireWoods LLP on

This is the 52nd in a series of WorkCite articles concerning the Patient Protection and Affordable Care Act and its companion statute, the Health Care and Education Reconciliation Act of 2010 (referred to collectively as the...more

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

The number of days until the U.S. House of Representatives returns from August recess. The Senate is in this week to tackle procedural motions for legislation related to cybersecurity and Planned Parenthood. The Senate is...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Tax Court Invalidates Stock-Based Compensation Amendment in Altera"

On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. §1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more

Polsinelli

Treasury And IRS Issue Final And Temporary Type III Supporting Organization Regulations

Polsinelli on

On December 21, 2012, the Department of Treasury and Internal Revenue Service issued final and temporary regulations regarding the requirements to qualify as a Type III supporting organization, which is one that is operated...more

Sherman & Howard L.L.C.

Proposed Regulations Would Promote Growth of Wellness Programs

Five federal agencies have collectively proposed regulations to implement elements of the Affordable Care Act ("ACA") healthcare reform legislation designed to encourage employers to sponsor employee wellness programs. The...more

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