News & Analysis as of

Internal Revenue Code (IRC) Tax Returns

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

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It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

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

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

Farrell Fritz, P.C. on

In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

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

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Freeman Law

Willful FBAR Penalties and the Excessive Fines Clause: District Court Says Context is Key

Freeman Law on

In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more

Chambliss, Bahner & Stophel, P.C.

Tax Break Helps Pay for CCRC Fees

A lesser-known financial upside of Continuing Care Retirement Community (CCRCs) is the potential tax deductibility of a portion of the entrance fee and monthly fees....more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

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Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Husch Blackwell LLP

IRS Cutbacks May Impact Healthcare M&A Transactions

Husch Blackwell LLP on

Kevin’s practice involves guiding clients through the complexities of federal, state, local and international taxation. Kevin routinely advises business entities, tax-exempt organizations and high net worth individuals on a...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Proskauer Rose LLP

Wealth Management Update - March 2025

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March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

Williams Mullen on

On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Proskauer - Tax Talks

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on

On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

McDermott Will & Emery

IRS Roundup February 10 – 14, 2025

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Overview of Federal Tax Filing Obligations for Political Action Committees

As those in the U.S. enter tax season, now is a good time to review and ensure company PACs are in compliance with federal tax law. As organizations that primarily engage in political activities, PACs are generally tax-exempt...more

Lathrop GPM

First Time Issuance of IRS Form for Elections Under Section 83(b)

Lathrop GPM on

For the first time, the IRS has issued an official form to be used for making an election under Section 83(b) of the Internal Revenue Code. Until the IRS issued Form 15620 in late 2024, taxpayers used their own “homemade”...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

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Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Gray Reed

Navigating the IRS On Your Own: 101

Gray Reed on

Headlines and updates on sweeping changes to operations and staffing with regards to numerous federal agencies, and now implementing new tariffs, as we enter tax filing season may have people even more on edge than years...more

McDermott Will & Emery

IRS Roundup January 20 – 31, 2025

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more

Allen Barron, Inc.

Will You Recognize the Form 1099-K When You Receive it This Year?

Allen Barron, Inc. on

Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year?  A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

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Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

McDermott Will & Emery

IRS Roundup January 13 – 17, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more

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