News & Analysis as of

Internal Revenue Service De Minimus Quantity Exemption

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.  
Faegre Drinker Biddle & Reath LLP

De Minimis Financial Incentives to Participate in a 401(k) or 403(b) Plan

On December 20, 2023, the IRS issued Notice 2024-2, which provides question-and-answer guidance on various aspects of the SECURE 2.0 Act. This post focuses on the “de minimis financial incentives” under SECURE 2.0 Act Section...more

King & Spalding

IRS and Treasury Issue Interim Guidance on 1% Stock Buyback Tax

King & Spalding on

On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more

Polsinelli

BitBlog Bi-Weekly Update - February 2020

Polsinelli on

Many crypto entrepreneurs are seeking to build decentralized networks in which a token serves as a means of exchange on, or provides access to a function of the network.  In the course of building out the network, they need...more

Troutman Pepper

Addition of UBTI Siloing Rules Creates New Challenges for Tax-Exempt Organizations - Tax Update Volume 2019, Issue 2

Troutman Pepper on

Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more

Foodman CPAs & Advisors

AICPA steps up to IRS to recommend that IRS provide Virtual Currency Clarity

On 5/30/18, the American Institute of CPAs (AICPA) sent a letter (https://www.aicpa.org/content/dam/aicpa/advocacy/tax/downloadabledocuments/20180530-aicpa-comment-letter-on-notice-2014-21-virtual-currency.pdf) to the IRS...more

Littler

Dear Littler: 'Tis the Season…for Employer Holiday Gift-Giving Reminders

Littler on

Dear Littler: I’m in charge of our company’s party-planning committee, but I’m ready to give up my title as Head Elf. We’re working on choosing gifts for employees, and we’d like to raffle off nice prizes for employees and...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Latham & Watkins LLP

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

Latham & Watkins LLP on

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

Eversheds Sutherland (US) LLP

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

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