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

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

TIGTA Releases Annual Report on IRS Compliance Trends

The Treasury Inspector General for Tax Administration (TIGTA) released its annual report on IRS compliance trends yesterday. The key takeaway from the report is TIGTA’s finding that the total amount of revenue received and...more

The New Landscape for Inversions: IRS and Treasury Change the Rules

The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

Treasury Announces Inversion Regulations; Reach Extends to Other Cross-Border M&A

New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions. On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more

IRS and Department of Treasury Release 2014-2015 Priority Guidance Plan

On August 26, 2014, the IRS and the Department of the Treasury issued the 2014-2015 Priority Guidance Plan. The Priority Guidance Plan includes 18 exempt organization law projects and four projects relating to charitable...more

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

Legal Alert: Final Rules on Compensation Deduction Limit for Health Insurers

The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain...more

Department of the Treasury and the Internal Revenue Service to Issue Regulations Limiting Taxpayers’ Ability to Benefit from...

On September 22, 2014 the Department of the Treasury and the Internal Revenue Service provided official notice to taxpayers of their intention to issue regulations limiting taxpayers’ ability to benefit from undertaking...more

Alert: IRS and Department of the Treasury Notice Limits Inversion Transactions

On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 14: IRS Notice 2014-55 Gets the Employer Shared Responsibility...

The Treasury Department and the IRS had a busy week issuing no less than five Affordable Care Act guidance items, consisting of...more

Update on Same-Sex Employee Benefits

In recent months employers around the country, have been scrambling to keep up with developments with respect to the evolving rights of employees in same-sex relationships. This articles touches on some recent guidance in...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 17: Cherry Bomb in the Gold Fish Pond, or Third-Party Staffing...

With two seemingly simple and straightforward definitions in the final regulations implementing the Affordable Care Act’s pay-or-play rules—i.e., definitions of “employer” and “employee”— the Treasury Department and IRS have...more

IRS Scripts a New Tune with Final Whistleblowing Regulations

Section 7623 of the Internal Revenue Code (the “Code”), added in 1954, authorizes the Treasury Secretary to pay an award as he deems necessary for “(1) detecting underpayments of tax, or (2) detecting and bringing to trial...more

Summary of New Money Market Fund Rules Adopted by the SEC

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds, in a release adopting amendments to Rule 2a-7 under the Investment Company...more

Mitigating Longevity Risk in DC Plans

401(k) participants face the risk of outliving retirement assets. However, earlier this month, the Internal Revenue Service and the Treasury Department issued final regulations that make it easier for 401(k) plans, individual...more

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

Of Mice and Elephants: Halbig and King and The Struggle of Two Federal Appeals Courts to Find Meaning in Words That May or May Not...

At issue in Halbig v. Burwell and King v. Burwell is whether or not subsidies to buy insurance on an exchange are available in both state and federal exchanges. On its face the Affordable Care Act (“ACA”) provides for...more

SEC Adopts Amendments to Money Market Fund Rules

The Securities and Exchange Commission (SEC) today adopted long-awaited and highly anticipated amendments to rules under the Investment Company Act of 1940 (the 1940 Act) governing money market funds. ...more

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 24: Can Offers of Group Health Plan Coverage Under Code...

The Employer Shared Responsibility provisions of the Affordable Care Act (“ACA”) generally require “applicable large employers” (i.e., employers who employed at least 50 full-time and full-time equivalent employees on...more

Offshore Asset Reporting: Rules, Enforcement, and Options for Compliance

In this presentation: -Overview: Reporting Regimes for Offshore Assets -Department of the Treasury: Report of Foreign Bank and Financial Accounts (FBAR) -Form 8938, Statement of Specified Foreign...more

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