News & Analysis as of

Federal Taxes

Cryptocurrency Exchanges - the New Front of the IRS War on Tax Evasion?

by Morrison & Foerster LLP on

On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more

Federal Employment Taxes: Employee-Independent Contractor Issues (Part 4)

by McNair Law Firm, P.A. on

IRS Voluntary Worker Classification Settlement Program - Employers that have workers which the employer classifies as “independent contractors” (Form 1099) risk having these workers reclassified by the IRS as employees....more

Tax Talk: Volume 10, Issue 3

by Morrison & Foerster LLP on

EDITOR’S NOTE - Tax Reform (or whatever you want to call it) is in full swing as this edition of Tax Talk goes to press. The House has passed H.R. 1 and the Senate Finance Committee has approved its own version of the Tax...more

Federal Employment Taxes: Employee-Independent Contractor Issues (Part 3)

by McNair Law Firm, P.A. on

IRS Form SS-8 Determinations of Employee Status - Employers that have workers which the employer classifies as “independent contractors” (Form 1099) risk having these workers reclassified by the IRS as “employees.” This...more

New SALT Implications in Proposed House and Senate Tax Reform Bills

by McDermott Will & Emery on

The federal tax reform legislation is a work in progress, and its final form will undoubtedly be affected by political considerations and lobbying by interested parties. Both the House and Senate bills deserve careful study...more

Federal Employment Taxes: Penalties and Interest (Part 2)

by McNair Law Firm, P.A. on

Employers that pay wages and other forms of compensation to their employees must comply with federal tax return filing and payment/deposit requirement. Employers that receive services from non-employee contractors and which...more

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 4

by Holland & Knight LLP on

The House of Representatives on Nov. 16, 2017, voted on and passed their tax reform bill, along party lines (227-205). Passage was expected in the House, where the GOP hold a significant enough majority needed to move the...more

Year-End Tax Planning, Tax Reform and Proposed 2704 Regulations Withdrawn

by Goodwin on

With the end of year approaching, now is the time to consider making gifts to lower your federal and state estate tax liability. That tax liability, however, could change with impending federal tax reform. Regardless of the...more

Senate Tax Proposal Hits Hospitals, Other Exempt Organizations

by King & Spalding on

On November 9, 2017, Republicans on the Senate Finance Committee announced their plan for reforming the Federal tax code, including several provisions that target charitable hospitals and other tax-exempt organizations. Like...more

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 3

by Holland & Knight LLP on

The Top Line - The House Ways and Means Committee completed its marathon "markup" of the tax-reform bill this week, paving the way for a floor vote on the measure as soon as next week....more

Federal Employment Taxes: Filing and Payment Requirements for Employers (Part 1)

by McNair Law Firm, P.A. on

Employers that pay wages and other forms of compensation to their employees must comply with federal tax return filing and payment/deposit requirement. Employers that receive services from non-employee contractors and make...more

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 2

by Holland & Knight LLP on

House GOP leaders on Thursday, Nov. 2, released their anticipated tax-reform proposal. Entitled the "Tax Cuts and Jobs Act," the House Bill includes several proposed changes to the corporate and individual tax system....more

Private Equity and Other Carried Interest Funds - Federal Tax Policy Tip Sheet: Issue 1

by Holland & Knight LLP on

The U.S. House of Representatives passed the Fiscal Year (FY) 2018 budget on Thursday, Oct. 26, 2017, clearing the congressional path for tax reform legislation and providing a procedural victory for President Donald Trump...more

You are Contacted by an IRS Criminal Investigator: What Do You Do? Defending an IRS Criminal Investigation (Part 11)

by McNair Law Firm, P.A. on

The IRS investigates criminal violations of federal tax laws, including tax evasion, tax fraud, and not filing tax returns. Many people do not realize that simply not filing a tax return when it is due is a crime under...more

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

by Holland & Knight LLP on

• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

Trump Administration Officials and Congressional Leaders Release “Unified Framework” for Tax Reform

by Morrison & Foerster LLP on

On September 27, 2017, a group of top Trump administration officials and key leaders from the House and Senate released an aspirational outline for future tax reform referred to as the “Unified Framework” (the “Framework”). ...more

Common U.S. Tax Withholding and Reporting Errors with Respect to Certain RSUs

by Dorsey & Whitney LLP on

A Canadian company (the employer) historically has not issued equity-based awards to employees of its U.S. subsidiaries, but it now is considering doing so. Past posts have addressed potential U.S. income tax pitfalls and the...more

State and Local Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform. The states conform to the federal tax laws to varying degrees and the extent to...more

Tax Law Uncertainty Should Not Delay Farming Business Succession Planning

by Downey Brand LLP on

President Trump promised and will pursue tax reform, but Congress must agree to any proposal. For the most part, a majority vote in both houses would allow tax reform for about a decade, and at least sixty Senate votes would...more

Hurricane Irma Client Alert: Tax Filing, Payment Deadlines Extended for Victims in Disaster Areas

by Morgan Lewis on

Victims of Hurricane Irma located in areas designated by the Federal Emergency Management Agency as qualifying for individual assistance now have until January 31, 2018 to file certain federal tax returns and make certain...more

Currently Not Collectible Taxes: What Do You Do? (Part 4)

by McNair Law Firm, P.A. on

If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can consider placing the account into “currently not collectible” (CNC) status. If placed in CNC status, a...more

Federal Tax Liens In Foreclosure Proceedings

by Ward and Smith, P.A. on

Henkel v. Triangle Homes is a North Carolina Court of Appeals case with dueling tax foreclosure proceedings involving the same property. One foreclosure proceeding was for unpaid municipal taxes and the other for unpaid...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...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

CBO Releases Updated Cost Estimate of American Health Care Act of 2017

On May 24, 2017, the Congressional Budget Office (“CBO”) and the staff of the Joint Committee on Taxation (“JCT”) released a cost estimate for H.R. 1628, known as the American Health Care Act of 2017 (the “AHCA”). The CBO and...more

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