News & Analysis as of

U.S. Treasury Internal Revenue Service

Reissuance of Proposed Regulations on Partnership Audit Rules

by Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

IRS Grants Extension Of Time To Acquired Group To Elect To Deduct 70-Percent Of Their Success-Based Advisor Fees

by Roetzel & Andress on

In Private Letter Ruling 201722002 (published June 2, 2017), the Internal Revenue Service (IRS) granted the taxpayer, a group of corporations that were acquired pursuant to a plan and agreement of merger and became wholly...more

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

by Proskauer - Tax Talks on

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit...more

Treasury Has No Authority to Collect PTIN Fees

by Charles (Chuck) Rubin on

Since 2010, federal tax return preparers have been required to obtain a Preparer Tax Identification Number (PTIN), which they include when signing a federal tax return. A fee has been charged, both to obtain an initial PTIN...more

Taxpayer Wish List

by Alston & Bird on

Taxpayers who have concrete suggestions for changes in tax regulations that would make life easier for their business activities should take this opportunity to inform the Treasury of those needs. Several Treasury officials...more

Treasury Inspector General Slams IRS for Lack of Strategy Following 2015 Data Breach

In a scathing report published on March 27, 2017, the Treasury Inspector General for Tax Administration blasted the Internal Revenue Service (IRS) following its analysis of the IRS’ steps following a data breach in 2015 that...more

New Regulations on Issue Price of Tax-Exempt Bonds

by Foley & Lardner LLP on

On December 9, 2016, the Department of the Treasury and Internal Revenue Service (IRS) published final regulations on the definition of “issue price,” for purposes of the arbitrage rules that apply to tax-exempt bonds....more

Proposed Regulations Update Mortality Tables, Minimum Present Value Requirements for Defined Benefit Pension Plans

by McDermott Will & Emery on

Near the end of 2016, the US Department of Treasury and the Internal Revenue Service published two significant sets of proposed regulations on issues pertaining to defined benefit pension plans, including mortality table...more

Last Day of Remedial Amendment Period for 403(b) Plans is March 31, 2020

by Jackson Lewis P.C. on

Eligible employers sponsoring Code Section 403(b) retirement plans have until March 31, 2020 to self-correct any defects as to the written form of those plans. In recently issued Revenue Procedure 2017-18, the IRS fixed March...more

Tax Guidance to Slow Under Trump. Even More Emphasis on Letter Rulings in Bond Transactions?

As the Trump administration attempts to substantially reduce the amount of federal regulations, both the Deputy Tax Legislative Counsel of the Treasury Department and an Associate Chief Counsel at the Internal Revenue Service...more

Do Tax Regs Have an Out From the New 2-1 Rule?

As I previously discussed (here), President Trump issued an Executive Order requiring government agencies to identify two regulations for repeal for every new regulation that they wish to issue. The initial reaction of this...more

IRS Announces the Last Day of the Remedial Amendment Period for 403(b) Plans

The Internal Revenue Service recently issued Revenue Procedure 2017-18, which provides that the last day of the remedial amendment period for Code Section 403(b) retirement plans will be March 31, 2020. As discussed below,...more

The New Issue Price Regulations: The Good, the Bad and the Ugly

by Bracewell LLP on

Late last year, the Treasury Department released final Treasury Regulations (the “New Regulations”) relating to the “issue price” of tax-exempt bonds, effective for bonds sold after June 7, 2017. Because the changes imposed...more

Final Regulations on MLP Qualifying Income Provide Clarification

Final regulations issued by the Treasury and the Internal Revenue Service (IRS) on January 19, 2017, revealed a set of new rules interpreting “qualifying income” under Section 7704(d) of the Internal Revenue Code, affecting...more

Treasury and IRS Release Final Regulations on Qualifying Income, but Halted by Trump Moratorium

by Bracewell LLP on

January 25, 2017 On January 19, 2017, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding qualifying income under Internal Revenue Code (Code) section...more

Midnight Regulations Provide Oil & Gas MLPs with Favorable Answers; New Administration Immediately Withdraws

On January 19, 2017, less than 24 hours before the change of administration, the IRS and Treasury released much-anticipated final regulations under Code section 7704(d)(1)(E) setting parameters for qualifying income for...more

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

by Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

A Reprieve from Proposed Regulations Related to Valuation of Family Businesses?

In December, we posted a blog discussing a much anticipated hearing held on the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704...more

New Temporary and Proposed Regulations Regarding Debt Allocations for Partnerships - 'Oh My' - Tax Update Volume 2017, Issue 1

by Pepper Hamilton LLP on

Although There Are Aspects of the Regulations that Practitioners and Taxpayers Still Disagree With, There Are Others that Are an Improvement on What Was Proposed Earlier. From 2013 through 2014, the IRS and the U.S....more

Treasury and DOL Update 2016-2017 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 October 31, 2016, the U.S. Department of the Treasury and the Internal Revenue Service...more

Lawsuit filed to set aside IRS Notice 2016-66

Two months ago, without any prior warning or public notice, the IRS issued Notice 2016-66 which defined a number of common captive insurance transactions as “transactions of interest.” The Notice is limited to captive...more

U.S. Antiboycott Compliance: New Federal List Published

by Polsinelli on

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities 

Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

by Alston & Bird on

On December 2, 2016, the Treasury issued Notice 2016-73, describing future regulations that will modify the Killer B regulation issued in 2011; the modifications will stymie newly discovered variations of the Killer B...more

36-Month Rule for Reporting Discharges of Indebtedness Is Repealed

by Shipman & Goodwin LLP on

The Treasury Department has issued proposed amendments to the regulations governing the reporting of discharges of indebtedness that will impact the filing of Forms 1099-C by member banks for the 2016 calendar year. In...more

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