News & Analysis as of

Internal Revenue Code (IRC) U.S. Treasury Compliance

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on

On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

Foodman CPAs & Advisors

FATCA Responsible Officer Certifications due 7/1/25

On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

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

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...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

Holland & Knight LLP

Final Regulations Issued on Penalty Supervisory Approval

Holland & Knight LLP on

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Foley & Lardner LLP

IRS Releases Proposed Regulations for Section 45V Hydrogen Production Credit

Foley & Lardner LLP on

Last week, the Internal Revenue Service (“IRS”) and Department of the Treasury published proposed regulations (the “Proposed Regulations”) relating to the tax credit for production of clean hydrogen under Section 45V of the...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations and Revenue Procedure on the Clean Vehicle Tax Credits under Section 30D of...

The proposed regulations add new definitions to clarify what is required under foreign entity of concern (FEOC) compliance. The Revenue Procedure provides guidance to qualified manufacturers on reporting and other...more

Kohrman Jackson & Krantz LLP

Treasury Provides Temporary Relief from 401(k) Catch-up Contributions Rollback - Update

The Secure 2.0 Act (Secure 2.0), a sweeping retirement bill included in Division T of the Consolidated Appropriations Act of 2023, was a major bipartisan accomplishment of the 117th Congress. The bill included 82 provisions...more

Foley & Lardner LLP

401(k) Compliance Check #12: Don’t Borrow Trouble – Correcting Retirement Plan Loan Errors

Foley & Lardner LLP on

In last month’s 401(k) Compliance Check, we discussed the importance of developing (and maintaining) best practices for handling beneficiary designations. This month, we discuss one of the most common problems faced by 401(k)...more

Bracewell LLP

Treasury and the IRS Fuel Taxpayers' Confidence Regarding Section 45Q Credits following Call for Suspension of the Credits

Bracewell LLP on

On May 28, 2020, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under Section 45Q of the Internal Revenue Code (Section 45Q) for the capture, utilization...more

Franczek P.C.

Department of Treasury Issues 2015-2016 Priority Planning Guide

Franczek P.C. on

The Department of the Treasury issued its 2015-2016 Priority Guidance Plan detailing projects that it intends on dedicating resources to in the coming year. There are numerous employee benefits-related items in the plan....more

Franczek P.C.

Employee Benefits Alert - July 2015

Franczek P.C. on

Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more

18 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide