News & Analysis as of

Internal Revenue Code (IRC) Treasury Regulations Income Taxes

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...

Foster Garvey PC on

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

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

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

Foster Garvey PC

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

Foster Garvey PC on

In this Part XII of my multi-part series on some of the not-so-obvious aspects of S corporations, I explore a consistent theme – taxpayers lose fights with taxing authorities when they fail to maintain adequate records....more

Freeman Law

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

Freeman Law on

Tax Litigation:  The Week of August 15th, 2022, through August 19th, 2022 Medtronic, Inc. v. Comm’r, T.C. Memo. 2022-84 | August 18, 2022 | Kerrigan, J. | Dkt. No. 6944-11. Short Summary: This opinion regards a transfer...more

Freeman Law

Tax Treaties and Exempt Income

Freeman Law on

Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more

Freeman Law

Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions

Freeman Law on

Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions - On March 11, 2022, the Joint Committee on Taxation published its 49-page report (the “Report”) relating to the federal tax treatment of...more

Freeman Law

IRS Issues Guidance on Self-Dealing Rules for Private Foundations

Freeman Law on

IRS Issues Guidance on Self-Dealing Rules for Private Foundations - On March 1, 2022, the IRS published its 128-page Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941. While not...more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

Snell & Wilmer on

The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

McDermott Will & Emery

Treasury and the IRS Release Final Foreign Tax Credit Regulations

McDermott Will & Emery on

Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

A&O Shearman

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

A&O Shearman on

On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – 30, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019. August 26, 2019: The IRS released a Treasury Decision in which it issued...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – 12, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8 – 12, 2019. July 9, 2019: The IRS updated its frequently asked questions page for the...more

Holland & Hart LLP

Understanding the Child Care Contribution Tax Credit

Holland & Hart LLP on

The Child Care Contribution Tax Credit (the “CCTC”) provides a valuable tax credit against a taxpayer’s Colorado state income tax. The credit equals 50% of the amount of a contribution made to a qualifying Colorado charitable...more

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