News & Analysis as of September 25, 2024

Taxation

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

Skadden, Arps, Slate, Meagher & Flom LLP on 6/25/2024

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

A Giant Eagle rematch? IRS Chief Counsel reiterates its disagreement with Third Circuit’s interpretation of all-events test

Eversheds Sutherland (US) LLP on 5/8/2024

On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more

Weekly IRS Roundup March 25 – March 29, 2024

McDermott Will & Emery on 4/3/2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more

Willful versus Non-Willful Conduct in the Eyes of the IRS

Allen Barron, Inc. on 2/22/2024

What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more

Weekly IRS Roundup November 13 – November 17, 2023

McDermott Will & Emery on 11/22/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more

Mo Money, Mo Problems? No Biggie for a Homeowner's Association, Right?

Ward and Smith, P.A. on 10/5/2023

Was your community association lucky enough to come in under budget last year? On the surface, this might appear to be a bonus, but if not handled properly, it can quickly turn into an unexpected tax burden. ...more

At the 10-Yard Line: New York Formally Proposes Corporate Tax Reform Regulations

McDermott Will & Emery on 8/14/2023

On August 9, 2023, the New York State Department of Taxation and Finance (Department) released 417 pages of proposed regulations, an important step toward concluding a now almost decade-long process to implement corporate tax...more

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

Rivkin Radler LLP on 3/27/2023

Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

Buckingham, Doolittle & Burroughs, LLC on 2/17/2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

Lista De Verificación De Preguntas Sobre Activos Digitales Del Formulario 1040 Del 2022

Foodman CPAs & Advisors on 2/2/2023

El Formulario 1040 2022 cambia la terminología criptográfica de “moneda virtual” a “activos digitales”. El propósito del cambio en la terminología podría interpretarse como un “aviso” a los contribuyentes de que el IRS está...more

IRS Raises Standard Mileage Rate for July to December 2022

Littler on 6/10/2022

On June 9, 2022, the Internal Revenue Service issued Announcement 2022-13, increasing the optional standard mileage rate for the final six months of 2022 from 58.5 cents per mile to 62.5 cents per mile. The new rate will be...more

Taxation of Cryptocurrency and Similar Transactions

Snell & Wilmer on 4/20/2022

Whether you’re an investor expanding your portfolio to include digital assets such as cryptocurrencies and tokens, a business that uses cryptocurrencies to engage in everyday transactions, or a crypto “miner," you need to...more

Taxation of NFT Creators

McDermott Will & Emery on 1/13/2022

NFTs offer artists, musicians, celebrities, influencers and other creators an opportunity to develop, market and control the future of many types of digital content that they produce. Less understood is how these assets will...more

Weekly IRS Roundup June 14 – June 18, 2021

McDermott Will & Emery on 6/21/2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 14, 2021 – June 18, 2021... June 14, 2021: The IRS issued a news release unveiling updates...more

Nobody Puts Baby In the Corner . . . And the IRS Agrees, Providing Guidance on the Taxability of Dependent Care Assistance...

Holland & Hart - The Benefits Dial on 5/11/2021

Yesterday the IRS released Notice 2021-26, which clarifies that if eligible dependent care benefits would have been excluded from income if used during either the prior tax year (2020 or 2021), these benefits remain...more

Dear Littler: Can Employees be Exempt from Income Tax?

Littler on 4/3/2019

Dear Littler: My company recently hired a new employee who is giving our human resources department some pushback on submitting his W-4. The HR manager says the employee mentioned something about not being subject to income...more

Privacy Tip #181- IRS Warns Consumers and Employers About Tax-Related Phishing Schemes

Robinson+Cole Data Privacy + Security Insider on 3/15/2019

In another round of warnings from the federal government on protecting yourself from tax return fraud and identity theft, the Internal Revenue Service (IRS) has issued its 2019 “Dirty Dozen” Campaign, designed to warn...more

Privacy Tip #180 – National Consumer Protection Week—Tax Identity Theft

Robinson+Cole Data Privacy + Security Insider on 3/11/2019

Last week was National Consumer Protection Week. In celebration of that, this post is devoted to protection from tax identity theft. ...more

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on 11/15/2018

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

New IRS Guidance Regarding Section 162(m)’s Deduction Limitation for Executive Compensation – Increased Complexity and Reduced...

Cadwalader, Wickersham & Taft LLP on 9/18/2018

The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more

U.S. Tax Court Finds Captive Insurer Is Not an “Insurance Company” Under the Internal Revenue Code

Carlton Fields on 7/26/2018

In this case, Reserve Mechanical Corp. (“Reserve”), a captive insurer incorporated under the laws of Anguilla, sued the Commissioner of Internal Revenue in the U.S. Tax Court regarding the Commissioner’s findings of $477,261...more

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