Tax Deductions Internal Revenue Service

News & Analysis as of

High Net Worth Family Tax Report, Vol. 10, No. 1

Recent Case Illustrates Importance of Keeping Legal Entities in Good Standing - A recent United States Tax Court case illustrates the importance of keeping legal entities in good standing. In Medical Weight Control...more

IRS Publishes Final Regulations Under Section 162(m)

On March 31, 2015, final regulations of Internal Revenue Code Section 162(m) were published. The final regulations clarify exceptions to the US$1 million annual limit on deductions allowable to publicly held corporations for...more

IRS Addresses Interaction of Performance Compensation and $1M Compensation Deduction Cap

The IRS recently issued final regulations under Section 162(m), which limits a public company’s deduction of executive compensation in excess of $1M.  The Section 162(m) limits do not apply to performance-based compensation...more

IRS Releases Clarifying 162(m) Regulations

The IRS recently released final regulations clarifying two aspects of the “performance-based compensation” exception to the $1,000,000 limit on deductible compensation paid to covered employees under Section 162(m) of the...more

"MassMutual Victory May Pave the Way for Earlier Deductions"

Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more

Executive Compensation Alert: IRS Releases Final Section 162(m) Regulations

Background - Section 162(m) of the Internal Revenue Code (the “Code”) denies a tax deduction to a public company if the compensation paid to its chief executive officer and three other highest compensated officers...more

Locke Lord QuickStudy: IRS Clarifies Performance-Based Compensation Exception Under Code Section 162(m)

On March 31, 2015, the Internal Revenue Service (IRS) published final regulations under Section 162(m) of the Internal Revenue Code (the Code). Code Section 162(m) disallows a deduction by any publicly-held corporation for...more

IRS Releases Amended Section 162(m) Regulations Clarifying How to Preserve the Deductibility of Certain Compensation for Public...

The Internal Revenue Service recently amended the regulations under Internal Revenue Code Section 162(m). Section 162(m) applies to publicly held companies and generally limits the tax deduction that a public company is...more

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more

Final IRS Regulations Under Section 162(m) Will Impact Transition Rule Applicable to Newly Public Companies

On March 31, 2015, the IRS issued final regulations under Section 162(m), the tax code provision which limits the deduction for compensation paid to certain public company executive officers. As signaled by the proposed...more

IRS Releases Final Regulations Clarifying 162(m) Limitation on Compensation

Section 162(m) of the Internal Revenue Code precludes the deduction by public companies for compensation paid to certain covered employees in excess of $1,000,000 in any taxable year. This limitation on deduction does not...more

Threat of Litigation Eliminates Charitable Set Aside Deduction for Estate

Estates and trusts with charitable beneficiaries often seek to employ the Code Section 642(c) charitable set aside deduction for income earned by the estate and trust that will eventually (but not in the current tax year) be...more

Family Tax Deductions and Credits: What Do You Qualify For?

Late last year, Congress approved nearly $11 billion to fund the Internal Revenue Service for fiscal year 2015 – the lowest allotted amount since 2008, according to CNN Money. As a result, the IRS announced delays in...more

Joint Obligors – Who Gets the Interest Deduction

In a recent Chief Council Advice, the IRS summarizes and reaffirms various principles that can be applied to determine who gets an interest deduction for payments made on a home mortgage when there is more than obligor under...more

Tax Law Blog: More 2015 Tax Numbers Released, Including Tax Brackets

I previously posted about the increase in retirement plan contribution limits for 2015. This week the IRS announced the tax brackets, personal exemption, and standard deduction amounts for tax year 2015. To be clear, the new...more

Recent Tax Developments

The following is a summary of the most important tax developments that have occurred in the past several months that may affect you, your family, your investments, and your livelihood. Please call us for more information...more

Proposed Section 752 Regulations and LIHTC Transactions: Part II

In a previous post earlier this week, I described the proposed regulations under Section 752 of the Internal Revenue Code (the “Proposed Regulations”), and in particular, the proposed changes to the rules regarding the...more

Final Regulations Issued For Investment Advisory Fees and Other Costs Incurred By Trusts and Estates Subject to the 2-Percent...

On May 8, 2014, the Internal Revenue Service published final Treasury Regulations, §1.67-4, prescribing when costs incurred by estates or nongrantor trusts are subject to the 2-percent floor for miscellaneous itemized...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

Tax Reform Proposal Takes Aim at Executive Compensation

On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more

IRS Signals a Potential End to Its Administrative Pursuit of the Separate Account DRD

On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more

Temporary vs. Indefinite – Lodging Expenses Away From Home

A taxpayer who travels away from his tax home overnight on business can deduct 50% of meals and 100% of lodging costs. A taxpayer’s “tax home” is located at (1) his regular or principal (if more than one regular) place of...more

Family Mortgages Come Under IRS Scrutiny

The IRS insists that i’s must be dotted and t’s crossed before the IRS will allow taxpayers to deduct mortgage interest on a “qualified residence.” If the formalities are not observed, the debtor may be denied a deduction...more

Tax Tip: Don't Lose Your Charitable Deduction for Lack of Paperwork - A message from tax attorney Paul Topolka, former District...

Charitable contributions are only deductible if you itemize and have the proper substantiation. For cash contributions of less than $250, you must have either a cancelled check/credit card receipt or a written...more

Same-Gender Marriage Implications for Employee Benefit Plans

In the summer of 2013, the Supreme Court issued a decision in U.S. v. Windsor, striking down a key provision of the Defense of Marriage Act (DOMA) and eliminating the requirement that federal law recognize only marriages...more

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