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Internal Revenue Code (IRC) Tax Code

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025

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Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Bricker Graydon LLP

Do I Need a 409A Valuation for my Company?

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If you have equity as part of your retirement or executive compensation plans, you likely need a 409A valuation. The need for a valuation also applies if you are preparing to issue equity (equity grants or stock options) or...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

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Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

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Last week I talked about the Grand Bargain to fix our business. If we’re fixing to fix our business now, we’ve got to talk REMIC. The Real Estate Mortgage Investment Conduit (REMIC) created as part of the Tax Reform Act of...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Dorsey & Whitney LLP

Considerations for Awarding Incentive Stock Options

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Canadian companies that award stock options to their employees, non‑employee directors and/or other service providers often inquire as to whether they should offer Incentive Stock Options (“ISOs”) to any such individuals who...more

Foster Garvey PC

A Birthday Greeting to the Tax Reform Act of 1986

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The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in...more

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Fleurinord Law PLLC

Understanding the Federal and State Tax Implications of Student Loan Forgiveness

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The idea of student loan forgiveness has caught the attention of many borrowers and sparked lots of discussions. If you're wondering how this might affect your taxes, you're not alone. It's important to know the rules and...more

Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Carlton Fields

Tax Court Upholds IRS Decision That Premiums Paid to Microcaptive Insurance Companies Did Not Qualify for Tax Deductions

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The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more

Foley Hoag LLP - Energy & Climate Counsel

IRS Issues Guidance and Requests Comment on Provisional Emission Rate Process for Hydrogen Tax Credit

On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...more

ArentFox Schiff

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

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The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

Troutman Pepper Locke

Navigating Cryptocurrency in the Marijuana Industry: Risks and Technological Solutions

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The marijuana industry has seen exponential growth over the past few years. However, the federal prohibition of marijuana poses significant challenges for businesses in this sector, in terms of payment processing and banking....more

Jackson Walker

What the IRS is Saying Lately about the Employee Retention Tax Credit

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The employee retention tax credit (“ERTC”) has garnered a lot of “buzz” lately – both from the IRS and businesses who have either received the credit or are seeking the credit. The buzz is well deserved, as the IRS has...more

Holland & Hart LLP

If You Want a Natural Medicine Company, Start Tax Planning Now

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A recent bill passed by Colorado voters allows for the establishment of a regulated market for plant-derived psychoactive substances. Potential owners of natural medicine companies should understand how Section 280E of the...more

Bowditch & Dewey

Massachusetts Taxpayers Find More Complexity in Differences Between Massachusetts and Federal Tax Law

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It seems every year there are changes to the Internal Revenue Code (IRC). It is a challenge, even for tax pros, to keep up with the ever-changing tax code. Massachusetts taxpayers also have an added challenge in keeping up...more

Verrill

Primer on Severance Plans Under ERISA and the Tax Code

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Many employers maintain formal or informal severance policies or practices that they use sporadically. Other employers may implement a severance program for a limited period of time to reduce the number of employees overall...more

Bradley Arant Boult Cummings LLP

IRS Answers Questions on Taxation of DCAPs and COVID-19 Relief

The Internal Revenue Service (IRS) has published Notice 2021-26 to provide answers regarding the taxability of benefits received in 2021 and 2022 under a dependent care assistance program (DCAP) that permits carryovers or...more

Foodman CPAs & Advisors

How does the IRS enforce the Nation’s Tax Laws for the benefit of all Taxpayers?

On December 17, 2020, the IRS published a document entitled “Closer Look”. It explains the IRS aspiration for balancing the Taxpayer burden with the potential benefit of its compliance effort when deciding which compliance...more

McDermott Will & Emery

IRS Reasserts That Forgivable PPP Expenses Are Not Deductible, but Is Legislative Relief on the Way?

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Loans under the Payroll Protection Program (PPP) are eligible for forgiveness depending upon whether and when the loan proceeds are used for qualified business expenses. One of the benefits of this program is that there is no...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

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Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

McDermott Will & Emery

Weekly IRS Roundup August 17 – August 21, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...more

McDermott Will & Emery

Weekly IRS Roundup July 27 – July 31, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 27, 2020 – July 31, 2020... July 28, 2020: The IRS issued final regulations providing...more

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