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Internal Revenue Code (IRC) Penalties Disclosure Requirements

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

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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...

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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

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

Freeman Law on

In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...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

Dechert LLP

Individuals and Trusts Beware: The Corporate Transparency Act Applies to You

Dechert LLP on

The Corporate Transparency Act (the "Act") is a significant piece of legislation enacted as part of the National Defense Authorization Act for Fiscal Year 2021. The Act was designed to prevent the misuse of corporations and...more

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