Internal Revenue Service U.S. 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.  
News & Analysis as of

The ACA’s Toyota tax

For several years now, employers have spent a great deal of time focusing on the Affordable Care Act’s (ACA) play-or-pay mandate. Numerous articles have been written and numerous educational seminars have been given...more

New Temporary and Proposed Regulations Offer Welcome Clarification on Application of the Embedded Loan Rule

On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to...more

MLP Qualifying Income – Treasury and IRS Issue Proposed Regulations

On May 5, 2015, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations that provide much-anticipated guidance on the scope of qualifying income under Section 7704(d)(1)(E) of the...more

Monthly Benefits Alert - April 2015

Central States Pension Fund Developing Rescue Plan - The Central States Pension Fund has announced that it will adopt a “rescue plan” under which certain participant benefits will be reduced. The Multiemployer Pension...more

IRS Proposes PFIC Regulations That Could Characterize Many Foreign Insurance Companies as PFICs

A mere 28 years after Congress enacted the tax rules governing passive foreign investment companies (“PFICs”), the Treasury Department and Internal Revenue Service have for the first time issued proposed regulations that...more

Treasury and the IRS Offer a New Take on the PFIC Active Insurance Exception

On April 23, Treasury and the IRS issued proposed regulations interpreting the active insurance exception under the passive foreign investment company (PFIC) rules. Although the release of the proposed regulations did not...more

Bitcoin and the Like: Tax Considerations

Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more

IRS Green Lights Section 529A ABLE Disability Programs

Pi Day comes but once a century, on 3/14/15. The Internal Revenue Service receives praise approximately as frequently. But the IRS deserves applause for its Notice 2015-18, released March 10, 2015, giving the green light to...more

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

Client Alert: IRS Announcement on February 9, 2015, Requires Review of Charter Schools Tax Status

On November 8, 2011, the IRS and Treasury Department published an Advance Notice of Proposed Rulemaking (“2011 Advance Notice”) that posed a threat to charter school participation in public pension plan systems. The 2011...more

Final Rule Sets Out Detailed Requirements for Charitable Hospitals

On December 31, 2014, the Treasury Department and the Internal Revenue Service (“IRS”) published a final rule (the “Final Rule”) implementing the requirements in Internal Revenue Code Section 501(r) for tax-exempt hospitals...more

"Challenging the IRS Anti-Inversion Notice: A Hollow Threat"

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...more

Creeping Normality: IRS Releases Final Regulations Under Section 501(r)

In This Issue: - Community Health Needs Assessments (Code Section 501(r)(3)) - Financial Assistance Policies (Code Section 501(r)(4)) - Limitation on Charges (Code Section 501(r)(5)) - Billing and Collection...more

IRS Issues Final Regulations for Charitable Hospitals

On December 29, 2014, the Internal Revenue Service and the Department of Treasury issued final regulations on requirements described in Section 501(r) for charitable hospitals exempt from federal income tax under Section...more

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more

The Treasury Department and the IRS Release Final Regulations Interpreting Internal Revenue Code Section 501(r)’s Requirements for...

On December 29, 2014, the Treasury Department and the IRS (collectively, the IRS) released final regulations under Internal Revenue Code Section 501(r) after taking into account comments received in response to proposed...more

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

Proposed Treasury Regulations Eliminate 36-Month Testing Period as a Trigger for Reporting COD Income - Removing the Non-Payment...

On October 15, 2014, the Internal Revenue Service (IRS) and the Department of the Treasury proposed to remove the deemed 36-month non-payment testing period from the list of identifiable events that trigger the requirement to...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more

"U.S. Corporate Inversion Update"

Numerous US legislative proposals have reacted to the perceived problems of US corporate inversions in which, generally, a parent USco becomes a Forco’s subsidiary. Not content to wait for enacted legislation, the IRS and the...more

Final Treasury Regulations Set Deadline for Arbitrage Rebate Overpayment Claims

Effective November 13, 2014, the filing deadline for a claim for an arbitrage rebate overpayment on tax-exempt and other tax-advantaged bonds is two years after the final arbitrage computation date for the issue from which...more

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

IRS and DOL Issue Favorable Guidance on Lifetime Income Provided Through Target Date Funds in Retirement Plans

On October 23 and 24, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued coordinated guidance on lifetime income provided through target date funds held by retirement plans. According to an...more

IRS Releases Highly Anticipated Cash Balance Plan Regulations

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently released long-awaited final regulations (the Final Regulations) with respect to market rates of return and related Pension Protection...more

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