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

Final Regulations Released Revising The Tax Treatment Of Sales-Based Royalties And Vendor Allowances

In December 2010, the IRS and Treasury proposed regulations that required the allocation of sales-based royalties and vendor allowances exclusively to property that has been sold (or for inventory property, deemed sold under...more

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more

IRS Issues Final Regulations on Property Transferred for Services Under Section 83

The Treasury Department (Treasury) and Internal Revenue Service (IRS) have issued final regulations clarifying the forfeiture provisions under Section 83 of the Internal Revenue Code of 1986, as amended, for transactions...more

FATCA regulations updated but deadlines loom

The US Department of the Treasury and the Internal Revenue Service have released what they refer to as the “last substantial package of regulations” necessary to implement the Foreign Account Tax Compliance Act (FATCA). ...more

"Treasury and IRS Release FATCA Regulations"

New Regulations Address Some Concerns and Coordinate FATCA Rules with Other Reporting and Withholding Rules - On February 20, 2014, the Department of the Treasury and the IRS issued a comprehensive set of final and...more

As Simple as Do-Re-Mi: Treasury and IRS Issue Final Rules on Employer Information Reporting under ACA

While no one would claim that understanding the Affordable Care Act (“ACA”) and all of its associated regulations is as simple as the chorus from a Jackson 5 song, the Treasury and the Internal Revenue Service announced final...more

Final ACA Shared Responsibility Regulations Released

Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more

The Top 10 Changes Made to the 2012 Proposed Rule Under the Affordable Care Act’s Employer Shared Responsibility Rules by Recently...

The Treasury Department and Internal Revenue Service recently issued final regulations implementing the employer shared responsibility provisions of the Affordable Care Act. For “applicable large employers” — i.e., those with...more

What Does The ACA Shared Responsibility Final Rule Mean To Large Employers?

As many small employers rejoice over a delayed effective date, large employers should be rolling up their sleeves to adapt their evolving shared responsibility compliance strategies for 2015 to a new final rule from the U.S....more

Playing Kick the Can with the Affordable Care Act: The Administration Further Delays Employer Deadlines

The Treasury Department has announced further extensions for medium-sized and large-sized employers for compliance with the “employer mandate” of the Affordable Care Act (“ACA”). The employer mandate requires employers with a...more

2014: Turbulent Waters Ahead in Tax Policy

Although the prospect for comprehensive tax reform this year is dimming, debate on tax policy issues will continue to be prominent on Capitol Hill. Between election year dynamics, changes in committee leadership, the tax...more

New Proposed Regulations Could Shake Up the Allocation of Partnership Debt

The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 45½: Treasury/IRS Issue Long-Awaited Final Regulations under...

Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more

Treasury Inspector General Report on 1603 Cash Grant Seems Off the Mark

On December 17, the Treasury Inspector General for Tax Administration released Review of Section 1603 Grants in Lieu of Energy Investment Tax Credit which is available below. Either there is some confusion associated with the...more

U.S. Department of Treasury Directed to Create "myRA"

New Retirement Savings Account Aimed at those Without Access to Such Plans Through Their Employer - President Obama announced in his State of the Union address that he would be ordering the Department of the Treasury...more

A New Way to Unwind (Leveraged Partnership Structures): Treasury and IRS Propose Draconian Changes to the Partnership Liability...

On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more

Proposed Treasury Regulations Could Significantly Impact Tax Deferral in Partnership Transactions

Late last month, the Treasury Department issued proposed regulations that address partnership liabilities (section 752) and disguised sales of property (Internal Revenue Code section 707). If enacted, the section 752...more

FBAR and Form 8938 Assistance Provided by Treasury

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

MyRA: A nice idea, but it won’t become popular

Regardless of which side of the political aisle created it, I like any product or plan that allows rank and file employees to save for retirement. President Obama made good on his State of the Union speech promise by...more

New Temporary Regulations Expand Reach of U.S. Anti-Inversion Rules and Permit De Minimis Continuing Ownership in Foreign Acquirer

On January 16, 2014, temporary regulations were issued by the U.S. Department of the Treasury and the Internal Revenue Service (IRS) with respect to corporate inversions under Section 7874 (the "New Regulations"), which...more

Section 752 Proposed Regulations Regarding Partnership Recourse Liabilities and Rules for Related Persons

On December 13, 2013, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations under Section 752 regarding recourse liabilities of a partnership and the special rules for related persons...more

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 49: Waiting for the Final Code Section 4980H Regulations

So where are they? Final regulations implementing the Affordable Care Act’s rules governing shared responsibility of employers were widely expected to have “dropped” before the beginning, or perhaps during the first...more

New Temporary Regulations Introduce a Welcome De Minimis Rollover-Shareholder Exception to US Anti Inversion Rules

On January 16, 2014, the Treasury Department and the Internal Revenue Service released new temporary regulations on one aspect of corporate inversions under Section 7874 (the “Regulations”) that altered and clarified the...more

IRS: No FTC For 3.8 Percent NIIT

No significant US tax changes are set to take effect in 2014; in contrast to last year, taxpayers are not standing on the edge of a fiscal cliff. Recently, however, the IRS released final Treasury regulations (TD 9644,...more

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