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

Integrated Health Reimbursement Accounts, Coordination with Family Coverage, and Notice 2015-87—Something’s Missing

Issued at the end of last year, Notice 2015-87 provided detailed guidance on a host of topics. The notice has been referred to colloquially in some quarters as the “pot luck” notice. Among other things, the notice, in Q&A 4,...more

Update: IRS Withdraws Proposed Regulations on Substantiation of Donations in Response to Taxpayer Comments

Back in September of 2015, the Treasury and IRS issued proposed regulations related to section 170(f)(8)(D) providing an alternate framework for substantiating charitable donations. The proposal would require a donee...more

DOL and Treasury Update 2015-2016 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. On November 19, 2015, the U.S. Department of Labor (DOL) updated its Semi-Annual...more

An Ounce of Prevention…Is Tax-Free: IRS Expands Tax Relief to Pre-Data Breach Identity Theft Protection Services

As reported here after last year’s customer data security breaches at major U.S. corporations, the IRS announced special tax relief for identity protection services provided to individuals affected by a security breach. In...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

Manatt on Health Reform: Weekly Highlights - December 2015 #3

Guidance from HHS and Treasury sets a high bar for 1332 waiver approvals; Kentuckians support Medicaid expansion and their State Marketplace despite plans to change course; and South Dakota's executive budget includes funds...more

Wealth Management Update - December 2015

December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more

Treasury Department and IRS Publish Final Hybrid Plan Regulations and Announce Extension of Required Amendment Date for Certain...

The Treasury Department and the IRS recently issued final regulations (the “2015 Final Regulations”) relating to hybrid retirement plans, including cash balance pension plans. The 2015 Final Regulations provide...more

Proposed Treasury Regulations Address Private Equity Management Fee Waivers and Profits Interests

The Internal Revenue Service ("IRS") and Treasury Department recently released proposed regulations under section 707(a)(2)(A) of the Internal Revenue Code of 1986 (the "Code) addressing the issuance of certain interests in...more

Treasury and IRS Issue Additional Inversion Notice

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more

ABLE Programs and Beneficiaries Boosted by Helpful Guidance from IRS and Social Security Administration

The Stephen Beck, Jr., Achieving a Better Life Experience Act of 2014 (ABLE Act), one of the few recent examples of bipartisan cooperation on a new category of tax and budget expenditure, is both well-intentioned in its...more

IRS and Treasury Issue More Guidance on “Inversion” Transactions

The Treasury Department and the Internal Revenue Service have issued additional guidance about so-called “inversion” transactions. Generally, an inversion transaction results where a U.S. corporation (“U.S. Target”) is...more

IRS Issues New Partnership Audit Procedures

Included as a revenue offset in the budget legislation (H.R. 1314) signed by President Obama are provisions that simplify the procedure for the Internal Revenue Service to audit and collect adjustments from partnerships. The...more

Where We Stand on Issue Price for Tax-Exempt Bonds

The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more

IRS Issues Final Regulations Regarding Allocation of Bond Proceeds to Mixed-Use Projects; SLGS Window Reopens

On October 26, 2015, the IRS released final regulations (the “Final Regulations”) regarding allocation and accounting rules for purposes of the private activity bond restrictions applicable to tax-exempt bonds issued by state...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

New Legislation Makes Sweeping Changes Impacting All Partnerships

All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

Treasury and the IRS Issue Proposed Regulations Implementing Supreme Court Same-Sex Marriage Ruling

In recent guidance, the Department of Treasury and the IRS issued proposed rules that clarify under the Internal Revenue Code (Code) that the terms “spouse” and “husband” and “wife” refer to individuals who are lawfully...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

New IRS Regulations for Mixed-Use Projects Financed With Tax-Exempt Bonds Have Practical Importance

On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant...more

Treasury Finalizes Regulations on the Varying Interests Rule Under Section 706

On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more

IRS Delays Effective Date for New Regulations on Embedded Loans in Swaps

The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 13 of 24): Coding Form 1095-C, Part II for...

Compliance with the Affordable Care Act’s (ACA) employer shared responsibility rules requires that applicable large employers identify their full-time employees. A “full-time employee” for this purpose is an employee who...more

IRS Issues Final Regulations on F Reorganizations

In September 2015, the Treasury Department and the IRS issued final regulations (T.D. 9739) that provide guidance with respect to the qualification of a transaction as a reorganization under Section 368(a)(1)(F) (an “F”...more

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