News & Analysis as of

Internal Revenue Code (IRC) Disclosure Requirements Tax Returns

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

Womble Bond Dickinson on

On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...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

ArentFox Schiff

IRS Loosens, and Tightens, Disclosure of Nonprofit Taxpayer Information

ArentFox Schiff on

On August 16, 2022, the Internal Revenue Service issued a final regulation on its ability to provide state governments with information regarding organizations seeking to become exempt and those already exempt from federal...more

Mayer Brown

The Taxpayer First Act and the Impact on Secondary Market Participants

Mayer Brown on

The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019.  The Act is designed, among other things, to overhaul and modernize...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Tax Practitioners May Use Return Information to Market to their Return Preparation Clients, But Some Use and Disclosures Require...

Accounting firms have specific rights and duties that come into play when they market to their clients using data gleaned from the return preparation process. The general rule is that returns and return information cannot be...more

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