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Internal Revenue Code (IRC)

Podcast - Chamber of Commerce v. Internal Revenue Service

by Ropes & Gray LLP on

In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for...more

Form 1023-EZ Revisions

by Bryan Cave on

The IRS revised Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions to help small charities apply for 501(c)(3) tax-exempt status....more

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Compensation Season 2018: Section 162(m) and Related Considerations Post-Tax Reform

by White & Case LLP on

On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law. The Act includes significant changes to the executive compensation deduction rules contained in §162(m) of the Internal Revenue Code (the...more

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Disposition of a Partnership Interest Now Subject to Tax Withholding

by K&L Gates LLP on

The new Tax Cut and Jobs Act of 2017 (the “Act”) contains a provision that is of great importance to any persons buying or selling an interest in a partnership. New Section 864(c)(8) of the U.S. Internal Revenue Code (the...more

Employers Beware: Tax Law Change Eliminates Tax Deductions Relating to Certain Settlements

by Dorsey & Whitney LLP on

The #MeToo movement has had far-reaching implications and appears to have influenced the new federal tax law. The legislation contains a provision that has received little attention but that may have serious, unintended...more

New and Proposed Tax Legislation Present New Difficulties for Employers Attempting to Settle Sexual Harassment Claims

by Ervin Cohen & Jessup LLP on

Most employers have heard of the Tax Cuts and Jobs Act, signed into law on December 22, 2017, and have contemplated what it may mean for them. What has been largely overlooked, however, is a denial of deduction buried deep in...more

Tax Cuts and Jobs Act: Impact on Tax-Exempt Organizations

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (the Act), which imposes a new excise tax on certain tax-exempt organizations for compensation paid to their covered employees in excess...more

New Partnership Audit Regulations Released as Permitting Push-Out Election Through Tiered Partnerships

by Ropes & Gray LLP on

In a trilogy of releases in the last six weeks, the Department of Treasury (“Treasury”) provided much-needed guidance on the implementation of the partnership audit rules in the Bipartisan Budget Act of 2015 (the “BBA...more

New Tax Act Bars Deductions for Settlements Related to Certain Sexual Harassment Claims

The recently enacted Tax Cuts and Jobs Act (the Act) has been touted as the largest tax reform since 1986. Among its many provisions, the Act adds a new section to the Internal Revenue Code (Section 162(q)) targeting...more

Plan Sponsors and Service Providers Must be Aware of Changes Made to Rules Pertaining to Puerto Rico Qualified Retirement Plans

by Littler on

Recent changes to Puerto Rico’s tax treatment of certain retirement plans have taken effect. Act No. 106 of August 23, 2017 (“Act 106”) amended Section 1081.01 of the Puerto Rico Internal Revenue Code as amended, (the “PR...more

Tax Cuts and Jobs Act Summary

by WilmerHale on

On December 22, 2017, President Trump signed sweeping tax reform legislation (H.R. 1) into law. The new law, commonly known as the Tax Cuts and Jobs Act (the “Tax Act”), makes significant changes to the Internal Revenue Code...more

IRS Issues Final Regulations For Electing Out Of Centralized Partnership Audit Regime

The IRS has issued final regulations under IRC § 6221(b), implementing rules for electing out of the new centralized partnership audit regime enacted under the Bipartisan Budget Act of 2015. The final regulations under IRC §...more

New Tax Law Prohibits Deduction for Sexual Harassment Settlements With Confidentiality Clauses

The new tax reform law contains a provision intended to address continuing concerns over sexual harassment in the workplace. Now employers that settle sexual harassment or sexual abuse claims with employees cannot deduct...more

UK charities seeking opinions on their equivalency to US tax-exempt charities

by DLA Piper on

On 2 October 2017, the IRS provided guidance to US tax advisers for issuing opinions to the effect that a non-US charity is equivalent to an analogous tax-exempt US charity (Rev. Proc. 2017-53, 2017-40 IRB 263). Few non-US...more

Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

by Mintz Levin on

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more

Reminder to Perform Annual ISO/ESPP Reporting in January 2018

As discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require Employers to annually furnish each employee who exercised...more

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Alert: Year-End Reporting for ISOs and ESPPs

by Cooley LLP on

This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to incentive stock option exercises and transfers of stock...more

Decoding the Tax Cuts and Jobs Act – Part II: IRC § 1031 and Tax Deferred Exchanges Take a Haircut

by Garvey Schubert Barer on

BACKGROUND - On February 21, 2014, then House Ways and Means Committee Chairman Dave Camp (R-Michigan) issued a discussion draft of the “Tax Reform Act of 2014.” The proposed legislation spanned almost 1,000 pages and...more

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Real Estate and Construction Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Technology Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

New Tax Reform Bill Stifles #MeToo Settlement Deductions

In acknowledgment of the recent sexual misconduct allegations and the confidential settlements in connection with those allegations, Congress added a new section 162(q) to the Internal Revenue Code as part of the Tax Cuts and...more

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