News & Analysis as of

Internal Revenue Code (IRC) Taxation

Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

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On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...more

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

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On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more

Jackson Lewis P.C.

Is the One Big Beautiful Bill Act an Employee Benefits Crystal Ball?

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Takeaways- • Republicans in the U.S. House of Representatives attempt to deliver on President Trump’s campaign promises in the One Big Beautiful Bill Act (BBB or the Act), which passed the House by a razor-thin margin of...more

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

DarrowEverett LLP

Business Succession Planning: Pros and Cons of Passing S Corp Shares in Trust

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Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...more

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

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Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more

Seward & Kissel LLP

Should you call 911 about Section 899?

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On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Sullivan & Worcester

Remediation of M&A REIT Targets (UPDATED)

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The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more

McDermott Will & Emery

Target LLCs as S Corporations: The Boilerplate Operating Agreement and the Importance of Revenue Procedure 2022-19

Many closely held businesses operate through entities classified as “S corporations,” an elective federal income tax regime that combines elements of corporate and partnership taxation. Among other reasons, S corporations are...more

Proskauer Rose LLP

Wealth Management Update - June 2025

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The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

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Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

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The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Skadden, Arps, Slate, Meagher & Flom LLP

The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill’s impact on investments in BDCs

On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill – sports industry sweats the over/under

As the “One Big Beautiful Bill” continues its legislative path through Congress, it remains too close to call on how the final legislation will impact the sports industry. On May 22, 2025, the House of Representatives...more

DLA Piper

House Passes Sweeping Tax Bill: Top Points for the Investment Funds Industry

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On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

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On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

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Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Freeman Law

Residency for Federal Taxation

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Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more

Pullman & Comley, LLC

IRS Announces HSA and HDHP Dollar Limits for 2026

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The IRS has announced the 2026 cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements...more

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 1 | 2025

Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more

Paul Hastings LLP

Crypto Tax Update – April 2025

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In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more

McDermott Will & Emery

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

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Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

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