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Final Rules Reporting Requirements Internal Revenue Service

Proskauer - Tax Talks

IRS and Treasury Announce Withdrawal of Related Party Basis Shifting Regulations

Proskauer - Tax Talks on

On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...more

Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

Williams Mullen on

On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Cadwalader, Wickersham & Taft LLP

Final Crypto Reporting Regulations for DeFi

On December 27, 2024, the Treasury and the IRS released final regulations (the “Final Regulations”) on reporting requirements for decentralized finance (“DeFi”) participants, accompanied by a press release, and Notice 2025-3,...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – December 27, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23, 2024 – December 27, 2024....more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations Applicable for Front-End Service Providers Facilitating Digital Asset and...

On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more

Fenwick & West LLP

IRS Final Broker Reporting Regulations for DeFi

Fenwick & West LLP on

The U.S. Treasury Department and the Internal Revenue Service (IRS) released final broker reporting regulations with respect to DeFi on December 27, 2024, in T.D. 10021. These final regulations apply to sales of digital...more

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

Seward & Kissel LLP on

The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

Fenwick & West LLP

Treasury’s Crypto Tax Reporting Rules Defer on DeFi

Fenwick & West LLP on

On June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final broker reporting regulations that mandate broker reporting for centralized exchanges and hosted wallet providers, providing...more

Holland & Hart - Employers' Lawyers

IRS Issues Final Prevailing Wage and Apprenticeship Regulations

On June 25, 2024, the Internal Revenue Service and U.S. Department of Treasury published final Treasury Regulations (“Final Regulations”) in the Federal Register on the prevailing wage and registered apprenticeship...more

Dickinson Wright

Corporate Transparency Act Compliance Date Is Approaching Quickly

Dickinson Wright on

Although the Corporate Transparency Act (CTA”) was adopted in 2021,  implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”)  established regulations. The deadline,...more

Polsinelli

New Form 5500 Rules Permit More Plans to Qualify for Audit Exemption

Polsinelli on

The Department of Labor, Internal Revenue Service, and Pension Benefit Guaranty Corporation recently issued final rules on employee benefit plan annual reporting requirements that are effective for plan years beginning on or...more

Lowenstein Sandler LLP

Preparing Your Company for FinCEN’s Beneficial Ownership Reporting Requirements

On September 29, 2022, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements...more

McDermott Will & Emery

IRS Issues Final Regulations Extending ACA Information Reporting Deadlines, Clarifies Additional ACA Issues

McDermott Will & Emery on

On December 15, 2022, the Internal Revenue Service (IRS) finalized regulations regarding Information Reporting of Health Insurance Coverage and Other Issues Under Internal Revenue Code (Code) Sections 5000A, 6055 and 6056...more

Fuerst Ittleman David & Joseph

FinCEN Issues Final Rule for Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more

Proskauer - Tax Talks

Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S....

Proskauer - Tax Talks on

On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more

Eversheds Sutherland (US) LLP

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

Proskauer Rose LLP

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

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

Dechert LLP

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

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