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Internal Revenue Service American Bar Association (ABA)

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.  
Proskauer Rose LLP

Wealth Management Update - September 2024 - 2

Proskauer Rose LLP on

September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more

Seward & Kissel LLP

DOJ Announces Launch of New “Gap-Filling” Whistleblower Program

Seward & Kissel LLP on

On March 7, 2024, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s 39th National Institute on White Collar Crime. In her address, she announced a new, nationwide...more

Cadwalader, Wickersham & Taft LLP

ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations

On December 20th, 2023, the American Bar Association Tax Section published detailed comments and recommendations (the “ABA Comments”) on the proposed crypto broker reporting regulations.  As discussed here, the New York State...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Issues Alert Analyzing When Circular 230 Applies to In-House Tax Professionals

The IRS Office of Professional Responsibility (“OPR”) has exclusive authority to administer and enforce Circular 230 (“Circ. 230”), the Regulations Governing Practice before the Internal Revenue Service. (31 C.F.R. Subtitle...more

Eversheds Sutherland (US) LLP

State of play: A May methods update 

At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more

Freeman Law

What are Common Ethical Issues in Tax Practice?

Freeman Law on

The nature of tax practice presents a number of unique ethical issues. Tax practice requires compliance with multiple ethical frameworks. This creates ambiguities and raises complex questions. Courts have even questioned...more

McDermott Will & Emery

Plaintiffs’ Lawyers Descend as DC Considers False Claims Act Expansion Again!

McDermott Will & Emery on

The D.C. Council is once again preparing to consider legislation (B23-0035; the False Claims Amendment Act of 2019) that would authorize tax-based false claims actions, allowing private, profit-motivated parties to bring...more

Foster Garvey PC

IRS Cleaning House at the Office of Professional Responsibility

Foster Garvey PC on

Earlier this year, rumors surfaced that the IRS plans to clean house and phase out all attorney positions from the Office of Professional Responsibility (“OPR”), an independent arm of the Service tasked with enforcing...more

Morgan Lewis

Controversial IRS Appeals Conference Pilot Program Extended for Another Year

Morgan Lewis on

At a recent American Bar Association Section of Taxation meeting in Washington, DC, Deputy Chief of the IRS Office of Appeals Andrew Keyso, Jr. discussed the extension of a pilot program that provides for the potential...more

Perkins Coie

Accounting Group Again Requests Guidance From The IRS on Virtual Currency Tax Issues

Perkins Coie on

The primary professional organization for accounting professionals (AICPA) recently renewed their requests to the Internal Revenue Service for U.S. virtual currency guidance on key tax issues. The IRS has not shown any...more

Ballard Spahr LLP

Request for IRS Guidance on LIHTC Issues

Ballard Spahr LLP on

Last week at the annual meeting of the American Bar Association Forum on Affordable Housing and Community Development (Forum), Michael Novey, Associate Tax Legislative Counsel, Office of Tax Policy, U.S. Department of the...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

Lowndes

Senators Call on IRS to Finalize Management Fee Waiver Regulations

Lowndes on

Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement? It is where a fund manager...more

BakerHostetler

Still Waiting For Guidance on Material Participation

BakerHostetler on

In March 2014, I commented on the US Tax Court decision in the Frank Aragona Trust case. In that case, the tax court disagreed with the Internal Revenue Service’s arguments that a trust was incapable of providing “personal...more

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