The End of COVID Waivers and Exceptions: What Now?
CF on Cyber: An Update on the Florida Security of Communications Act (FSCA)
Podcast: CMS and OIG Final Rules for Innovating Your Value-Based Payment Program - Diagnosing Health Care
Updates to Paid Leave Requirements Under FFCRA
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
[WEBINAR] Exploring the CPRA’s Investigatory Privilege
Jones Day Talks Health Care: The Eliminating Kickbacks in Recovery Act
Withholding Under Code Sections 1446(a) and 1446(f) A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more
SECURE 2.0 provided employees better access to liquid assets during a major life crisis. We have previously discussed the domestic abuse victim distribution exemption and the emergency personal expense distribution exemption...more
When the IRS published proposed regulations harmonizing key provisions of Code Sections 409A and 457(f) in 2016, executive compensation lawyers and consultants rejoiced. It was not just that a long wait was over (roughly nine...more
Hedge funds and private equity groups have long used the “limited partner exception” to minimize self-employment taxes, but on March 13, 2018, the IRS announced that it was going to increase its scrutiny on taxpayers...more
Although the Internal Revenue Service (IRS) has postponed broker-related digital asset reporting, a less publicized requirement that applies long-standing reporting rules for physical cash payments to businesses that accept...more
On August 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (the ‘‘Act’’), which aims to mitigate climate change, lower health care costs, and reduce the national deficit. The Act’s spending...more
An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and for eligibility for certain treaty...more
The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more
One of the biggest strikes against multiple employer plans (MEPs) may go the way of bellbottoms and Betamax. The Internal Revenue Service is proposing an exception to the one bad apple rule, which means that the action of...more
On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that include guidance on the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 1 – 5, 2019. July 2, 2019: The IRS issued a Chief Counsel Notice wherein the Chief...more
One of the most important rights a taxpayer has during the Internal Revenue Service (“IRS”) administrative collection process is to be notified of their right to a collection due process hearing before the IRS issues a levy....more
As described in a blog post on March 13, 2018, Section 13306 Tax Cuts and Jobs Act, P.L. 115-97 (Dec. 22, 2017) revises the longstanding rule on the deductibility as a business expense (or lack thereof) of "any fine or...more
On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more
The Protecting Americans from Tax Hikes (“PATH”) Act of 2015, enacted in December 2015, requires organizations to notify the IRS if they desire to operate under Section 501(c)(4) of the Internal Revenue Code (“Code”). (Only...more
It was widely reported that on the June 5 episode of the HBO program, Last Week Tonight, John Oliver forgave nearly $15 million of medical debt. That’s not quite right. This blog explains what really happened and why the...more
Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more
Mid-year changes to safe harbor 401(k) plans have long been thought to be available in only very limited circumstances. However, the IRS recently released guidance in Notice 2016-16 that significantly increases the scope of...more
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
What Private Equity Funds Should Know About ERISA: Basics of ERISA Coverage - The Employee Retirement Income Security Act of 1974, as amended (ERISA) imposes numerous duties on fiduciaries holding employee benefit...more
In a set of rules published last week, the government finalized a July 2010 interim final rule (“IFR”) related to coverage of certain preventive services and an August 2014 IFR regarding the definition of an eligible...more
Alden Bianchi, Chair of the our Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance carriers and...more
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.”...more