News & Analysis as of

New IRS Standards for Qualified Management Contracts

A few weeks ago the Internal Revenue Service released a new notice with allows 501(c)(3) organizations with tax-exempt bonds greater flexibility in drafting their management agreements. In the past, entities with outstanding...more

What Every Business Owner Needs to Know About Implementing the New Tangible Property Regulations

Over the last several years, the IRS has published a series of regulations and rulings that dramatically change how taxpayers must account for the costs of acquiring, repairing, improving and even disposing of tangible...more

Internal Revenue Service Releases Notice Liberalizing the Private Business Use

On October 24, 2014, the Internal Revenue Service (“IRS”) released Notice 2014-67 (the “Notice”), providing guidance with respect to Accountable Care Organizations and their use of tax-exempt bond financed projects. The...more

IRS Releases Favorable Private Business Use Rules for Facilities Financed With Tax-Exempt Bonds

On October 24, 2014, the IRS released Notice 2014-67, which establishes more favorable safe harbors for types of service contracts and other arrangements using property financed with tax-exempt bonds. The Notice also provides...more

Notice 2014-67 ?? Safe Harbors for ACOs and a New Management Contract Safe Harbor for Everyone

On Friday, Oct. 24, 2014, the Internal Revenue Service released interim guidance, Notice 2014-67, on whether a state or local government entity or an organization described in §501(c)(3) of the Internal Revenue Code of 1986,...more

Affordable Care Act in Mergers and Acquisitions: New Guidance from Internal Revenue Service

In Notice 2014-49, the Internal Revenue Service (“Service”) issued guidance on how to avoid potential penalties under the Affordable Care Act (“ACA”) in connection with mergers and acquisitions (“M&A”). The notice provides a...more

IRS Seeking Comments on Business Hardship Rules for Safe Harbor Defined Contribution Plans

The IRS is seeking comments on rules that permit sponsors of 401(k) plans to reduce or suspend safe harbor contributions in the middle of the plan year. As we wrote in a previous alert, under rules issued in November of 2013,...more

IRS Comments on its PTC Start of Construction Guidance

On August 20, the American Wind Energy Association (AWEA) held a webinar to discuss Internal Revenue Service (IRS) Notice 2014-46, which clarified the rules for wind projects to be grandfathered for production tax credit...more

Monthly Benefits Update - July 2014

Two federal appeals courts issued contradictory rulings on the validity of subsidies for the purchase of health insurance under the federal marketplace established pursuant to the Affordable Care Act (ACA). On July 22, a...more

Senate Finance Committee Considering Measure to Largely Repeal IRC Section 530 Safe Harbor for Most Businesses Using Independent...

Sen. Sherrod Brown (D.Ohio) reintroduced the “Fair Playing Field Act,” S.1706, in November 2013. The bill, which first appeared in 2010 under then-Senator John Kerry’s sponsorship, purports to close an ostensible loophole in...more

In Final Guidance, IRS Broadens General Welfare Safe Harbors for Tribal Programs - New Guidance Provides Planning Opportunities...

After receiving more than 120 written comments on how the IRS should apply the general welfare exclusion to Indian tribal government programs, the IRS has issued final guidance detailing how tribal programs may take advantage...more

More Guidance on the Windsor Decision: Mid-Year Amendments to Safe Harbor Plans

The Internal Revenue Service (“IRS”) has issued Notice 2014-37 to provide guidance on amendments to reflect the outcome of United States v. Windsor, which invalidated Section 3 of the Defense of Marriage Act regarding the...more

Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

BankinBits First Quarter Recap

The BankinBits blog, which discusses recent developments in the banking industry, has within the first quarter of 2014 addressed a diverse range of topics including banking services for the marijuana industry, the shuttering...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 37: Stalking the Elusive “Variable Hour Employee”

For “applicable large employers” (i.e., generally, those employers who employed an average of at least 50 full-time employees on business days during the preceding calendar year), determining which employees are “full-time”...more

IRS Offers Two New Due Diligence Safe Harbor Procedures for Accepting Rollovers into Qualified Plans

On April 3, 2014, the Internal Revenue Service released Revenue Ruling 2014-9 (the Ruling), which provides guidance helpful to the administration of rollovers by tax-qualified retirement plans by...more

New IRS Guidance Offers Insight Regarding Covered Transactions Under the Transaction Cost Regulations

When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally...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 Addresses Correction Method For Failure To Timely Provide Safe Harbor 401(k) Notice

In its retirement plan newsletter, the IRS stated that plan sponsors of safe harbor 401(k) plans who fail to issue safe harbor notices to employees on a timely basis may be required to make different corrections for different...more

IRS Changes Course And Provides Safe Harbor For "Real Estate Professionals" In Net Investment Tax Final Regulations

Section 1411 of the Patient Protection and Affordable Care Act (the "ACA") levies a new 3.8% tax on "net investment income" (the "NII Tax"). Among other things, the net investment income subject to the NII Tax includes...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

IRS Provides Discharge of Indebtedness Safe Harbor for Debt Secured by Interest in Disregarded Entity Holding Real Property

In general, discharge of indebtedness income is excluded from the gross income of a taxpayer (other than a C corporation) if the indebtedness is qualified real property business indebtedness (QRPBI). To qualify as QRPBI, the...more

IRS Final Rule Partially Delays ACA Employer Shared Responsibility Requirement

On January 10, 2014, the Internal Revenue Service (IRS) released final regulations governing the employer shared responsibility provisions of the Affordable Care Act (ACA). The final rule addresses application of the...more

IRS Provides Safe Harbor for Exclusion from Cancellation of Indebtedness Income

Rev. Proc. 2014-20, released on February 5, provides guidance regarding whether debt secured by an interest in a disregarded entity that holds real estate — rather than by the real estate itself — qualifies for the exclusion...more

IRS Issues Long-Promised Guidance Following Historic Boardwalk Decision

To welcome in the new year, the Internal Revenue Service (the “IRS”) issued Rev. Proc. 2014-12, 2014-3 I.R.B. 415, to provide administrative guidance to the federal historic tax credit industry in the aftermath of the Third...more

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