News & Analysis as of

Interim Guidance Internal Revenue Code (IRC)

Stinson LLP

IRS Issues Interim Guidance on Specified Research or Experimental Expenditures

Stinson LLP on

The Internal Revenue Service (IRS) recently announced in Notice 2023-63 (notice) that proposed regulations regarding specified research or experimental (SRE) expenditures would be forthcoming. Until then, taxpayers may rely...more

Cadwalader, Wickersham & Taft LLP

Notice 2023-2 Provides Helpful Guidance Regarding the Stock Repurchase Excise Tax

On December 27, 2022, Treasury issued interim guidance regarding the new excise tax on stock “repurchases” after December 31, 2022 in the form of Notice 2023-2, which taxpayers can rely on until Treasury publishes additional...more

Bracewell LLP

IRS and Treasury Department Release Initial Guidance for Labor Requirements under Inflation Reduction Act

Bracewell LLP on

On November 30, 2022, the IRS and the Treasury Department published Notice 2022-61 (the Notice) in the Federal Register. The Notice provides guidance regarding the prevailing wage requirements (the Prevailing Wage...more

BCLP

Church Waivers for Refund Claims and Abatement Requests

BCLP on

On July 15, 2020, the IRS issued interim guidance (IG) providing instructions to examiners on how to inform churches of the option to authorize the Service to consider church claims for refund or requests for abatement...more

Schwabe, Williamson & Wyatt PC

PPP Loan Rules Clarified for Fishing Boat Owners/Operators; OSHA and CDC Interim Guidance for Seafood Processors

Paycheck Protection Program Loans – Certain Fishing Boat Owners and Certain Crewmembers - For fishing boat owners and operators who obtained (or who are contemplating applying for) a forgivable Paycheck Protection Program...more

Verrill

IRS Guidance Regarding the Section 4960 Excise Tax Is (Somewhat) Helpful

Verrill on

IRS Notice 2019-09 provides guidance intended to help “applicable tax-exempt employers” determine whether compensation paid to their most highly compensated employees will be subject to the 21 percent excise tax imposed under...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Notice Offers Good News for State Colleges and Universities (at Least for Now)

In January 2019, the Internal Revenue Service (IRS) issued Notice 2019-09, which provides interim guidance for Section 4960 of the Internal Revenue Code of 1986. As a reminder, Section 4960 imposes an excise tax of 21 percent...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

Holland & Knight LLP on

• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more

Katten Muchin Rosenman LLP

Interim IRS Guidance on New Executive Compensation Requirements for Tax-Exempt Entities Creates New Challenges

Under new Section 4960 ("Section 4960") of the Internal Revenue Code of 1986, as amended ("IRC") that was adopted as part of the Tax Cuts and Jobs Act of 2017 (Tax Act), an excise tax under IRC Section 11 (currently 21...more

Eversheds Sutherland (US) LLP

Treasury and IRS issue interim guidance on executive compensation excise tax under section 4960

On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more

Snell & Wilmer

New IRS Guidance Throws a Pass to Certain Universities That Pay Coaches Compensation in Excess of $1,000,000

Snell & Wilmer on

In Notice 2019-09 (“Notice”), the IRS provides relief from the new excise tax to certain colleges and universities that pay their “covered employees” more than $1 million per year or pay excess parachute payments....more

Carlton Fields

IRS Issues Interim Guidance On Certain 2017 Tax Act Changes Affecting Exempt Organizations: Excess Remuneration and Parachute...

Carlton Fields on

The IRS issued Notice 2019-09, which provides interim guidance in a fairly lengthy Q&A format relating to Code Section 4960, enacted on December 22, 2017....more

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