News & Analysis as of

Internal Revenue Service

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  

Estate Tax Changes Past, Present, and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

House and Senate Tax Bills Target Renewable Energy Projects

by Holland & Knight LLP on

The U.S. Senate passed its version of a bill to overhaul the U.S. tax code on Dec. 2, 2017, and is now working with the House of Representatives to reconcile its bill with the House's version, passed in November. The goal of...more

Corporate Law & Governance Update - December 2017

by McDermott Will & Emery on

Unprecedented 2018 Board Challenges - The health system board should be prepared to address an extraordinary number of significant, enterprise-level challenges that are expected to arise in 2018. These challenges will...more

Cryptocurrency Exchanges - the New Front of the IRS War on Tax Evasion?

by Morrison & Foerster LLP on

On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more

IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

Early New Year’s Resolution: Update Partnership and LLC Agreements to Comply with New IRS Audit Rules

In 2015, Congress repealed the complex and heavily criticized Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) partnership-level audit rules which apply to partnerships and most LLCs. The new audit rules, which...more

Bipartisan House Bill Addresses Syndicated Conservation Easement Tax Shelters

by Coblentz Patch Duffy & Bass on

Last week, Representative Mike Kelly (R) of Pennsylvania and Representative Mike Thompson (D) of California introduced the Charitable Conservation Easement Program Integrity Act of 2017 as H.R. 4459. The Act is simple;...more

Donor Advised Funds May Face New IRS Rules

by Faegre Baker Daniels on

On December 4, 2017, the Treasury Department and Internal Revenue Service (IRS) issued Notice 2017-73, new proposed guidance for donor advised funds (DAFs). The public has the opportunity to comment on the following proposed...more

Federal Employment Taxes: Employee-Independent Contractor Issues (Part 4)

by McNair Law Firm, P.A. on

IRS Voluntary Worker Classification Settlement Program - Employers that have workers which the employer classifies as “independent contractors” (Form 1099) risk having these workers reclassified by the IRS as employees....more

U.S. v. Coinbase: Virtual Currency Holders Not Outside the IRS’s Reach

by Dechert LLP on

The U.S. District Court for the Northern District of California, on November 28, 2017, ordered the international digital currency broker, Coinbase, Inc., to produce to the Internal Revenue Service (IRS) the records of...more

IRS Updates Employer Shared Responsibility Payment Information

by Ropes & Gray LLP on

Last month, the IRS provided guidance regarding the procedures it will use to propose and assess employer shared responsibility payments under the Affordable Care Act (“ACA”). More recently, the IRS issued sample Forms 14764,...more

Five Things to Know about the Tax Cuts and Jobs Act

Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more

Reminder: The New Partnership Audit Rules Are Effective for Tax Years Beginning January 1, 2018

by Epstein Becker & Green on

The Bipartisan Budget Act of 2015 (“BBA”), enacted on November 2, 2015, provided for sweeping changes to the way partnerships are audited, including the ability of the Internal Revenue Service (“IRS”) to levy U.S. federal...more

Update: IRS Announces Employee Benefit Plan Limits for 2018

by McDermott Will & Emery on

On Monday, November 27, 2017, the Social Security Administration announced that the it is lowering the maximum amount of earnings subject to the Social Security tax for 2018 to $128,400. The Social Security Administration...more

More Scrutiny of Donor Advised Funds

by Bryan Cave on

Notice 2017-73, released on December 4, 2017, describes potential approaches that may be taken to address issues raised regarding the use of donor advised funds (“DAF”). The Treasury and IRS are considering developing...more

Watch out for IRS letters: IRS Begins Enforcing Employer Mandate

by FordHarrison on

The IRS has recently begun enforcing the “employer shared responsibility” (ESR) provisions of the Affordable Care Act (the "Act"), which require employers having 50 or more full-time employees (or full-time equivalent...more

IRS Issues Request for Comments Regarding the Regulation of Donor Advised Funds

The Internal Revenue Service (the “IRS”) has issued Notice 2017-73 (the “Notice”) which outlines approaches the Department of the Treasury (“Treasury”) and the IRS are considering with respect to the regulation of certain...more

‘Tis the Season for ACA Penalties

by Polsinelli on

After several years of uncertainty surrounding enforcement of the Patient Protection & Affordable Care Act of 2010’s so-called “employer mandate,” the Internal Revenue Service (IRS) has begun assessing penalty notices for the...more

ACA Employer Mandate Penalty Letters Coming Before Year-End!

by SmithAmundsen LLC on

With only 30-days to respond, employers should be watching their mail for Affordable Care Act (ACA) employer mandate penalty letters (IRS Letter 226J), coming before the end of 2017. Recent updates to the “Questions and...more

November 2017: The Top 14 Labor And Employment Law Stories

by Fisher Phillips on

It’s hard to keep up with all the recent changes to labor and employment law. While the law always seems to evolve at a rapid pace, there have been an unprecedented number of changes each month in 2017. November was no...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

by Proskauer - Tax Talks on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

Court Enforces — Partially — IRS “John Doe” Summons Served on Virtual Currency Exchanger

by Ballard Spahr LLP on

Last week, a federal magistrate judge in the Northern District of California granted in part and denied in part a motion by the IRS to enforce a “John Doe” summons served on Coinbase, Inc., which operates a virtual currency...more

IRS and Treasury Department Release Notice Regarding Donor Advised Funds

by Morgan Lewis on

In addition to sponsoring organizations of donor advised funds, the Notice may also impact donors and other tax-exempt organizations, including both private foundations and public charities; affected parties should submit...more

Plan Your Changes Before Changing Your Plans

by Balch & Bingham LLP on

There’s a comically profound scene in the second “Madagascar” movie. Penguin (management) and monkey (union) committees are negotiating a labor contract. After the monkeys seem to have secured what they want, they add a...more

“Whoaaa, Nellie!” Before Submitting Form 14765 …

by Balch & Bingham LLP on

Entering a football stadium many years ago, your nimble correspondent encountered unarmed security contractors wearing uniforms featuring the company logo – a big, red bull’s-eye – on the front of the baseball cap and on the...more

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