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Reporting Requirements Internal Revenue Service

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Fox Rothschild LLP

FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split

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For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more

Woodruff Sawyer

​​​​​IRS Issues Affordability Percentage Adjustment for 2025

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The Internal Revenue Service (IRS) has released Rev. Proc. 2024-35, which contains the inflation adjusted amounts for 2025 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable...more

Foodman CPAs & Advisors

Reportaje de Broker de Activos Digitales

El 6/28/24, el Tesoro de los EE. UU. y el IRS emitieron regulaciones finales con una fecha de vigencia del 9/9/24 que requieren que los brokers de custodia reporten las ventas e intercambios de activos digitales a partir del...more

Foodman CPAs & Advisors

Digital Assets Broker Reporting

On 6/28/24, the U.S. Treasury and the IRS issued final regulations with an effective date of 9/9/24 requiring custodial brokers to report sales and exchanges of digital assets beginning in calendar year 2025. Meaning,...more

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

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The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

McGlinchey Stafford

Is a “Tip” Paid in Cryptocurrency a Tip for Employment Tax Purposes?

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Tips are in the news lately. It seems like political strategists on both sides of the aisle have concluded that excluding tips from taxable income is good for votes. One has to wonder if this political promise will go the way...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

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On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Holland & Knight LLP

IRS Releases Long-Awaited Section 45Q LCA Procedures

Holland & Knight LLP on

The IRS on July 24, 2024, released Notice 2024-60, which provides Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses the information that must be included in the required life...more

Holland & Knight LLP

New FinCEN FAQ Guidance: Taxpayer ID Numbers, Disregarded Entities and Best Practices

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 24, 2024, issued two new FAQs providing guidance on 1) how to obtain a taxpayer identification number (TIN) in a manner to ensure...more

Saul Ewing LLP

Public Companies Quarterly Update (Q2 2024)

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Welcome to Saul Ewing’s Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware. This edition is related to...more

Seyfarth Shaw LLP

Demystifying the Corporate Transparency Act for Tax-Exempt Organizations – Part 2: CTA Compliance for Subsidiaries of Tax-Exempt...

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This article provides Corporate Transparency Act (CTA) guidance to tax-exempt organizations with subsidiaries. For a general overview of CTA compliance for nonprofit and tax-exempt organizations, please see Part 1: When to...more

Seyfarth Shaw LLP

Demystifying the Corporate Transparency Act for Tax-Exempt Organizations – Part 1: When to File a Beneficial Ownership Information...

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The Corporate Transparency Act (CTA) took effect on January 1, 2024 and some U.S. nonprofits and tax-exempt organizations are still debating how the CTA applies to them. This article provides newly-formed and existing...more

Freeman Law

Treasury and IRS Issue Final Digital Asset Reporting Regulations

Freeman Law on

The Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently published final regulations requiring brokers to file information returns and issue payee statements containing information regarding...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - June 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Cadwalader, Wickersham & Taft LLP

Finally Final Crypto Reporting Regulations

On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more

Eversheds Sutherland (US) LLP

Swiss sign Model 1 IGA with United States and resolve transition issues

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

McGlinchey Stafford

TIGTA Reports: Virtual Currency Tax Compliance Enforcement Can Be Improved

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The number of virtual currency types has added to this problem. According to TIGTA, the number of virtual currencies has grown significantly since April 2020, from 5,000 to over 26,000 (420 percent) as of July 2023. The two...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

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In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Vinson & Elkins LLP

The Very Timely PWA Requirements Finalized

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On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Foodman CPAs & Advisors

Práctica IRS Divulgación Voluntaria

Los contribuyentes que intencionalmente han no han cumplido con obligaciones tributarias o relacionadas con impuestos pueden resolver su incumplimiento y limitar su exposición a un proceso penal presentando una solicitud a la...more

Paul Hastings LLP

FinCEN Throws Another Curveball: Beneficial Ownership Reporting for Dissolved Companies

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This week, FinCEN issued new FAQs interpreting the obligations of the Corporate Transparency Act (“CTA”) that would require entities that were dissolved prior to the due date of the beneficial ownership initial report (“BOI...more

Blank Rome LLP

Updated Reporting Requirements for Foreign Gifts and Foreign Trusts

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Proposed Treasury Regulations (the “Proposed Regulations”) have recently been issued to update and clarify existing reporting obligations for U.S. persons who receive gifts from abroad or who are owners or beneficiaries of...more

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