News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Financial Institutions

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.  
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

Vorys, Sater, Seymour and Pease LLP

The Importance of Actively Monitoring S Corporation Compliance

Many banks have elected to be “S Corporations” for tax purposes. This status can provide significant tax benefits to the bank’s shareholders, but it also comes with several ongoing technical requirements. Failure to satisfy...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Freeman Law

OECD Proposes Rules for Intermediary Crypto-Asset Reporting, Due Diligence

Freeman Law on

On March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more

Pullman & Comley, LLC

Update on the Reconciliation Package: Municipal Bonding Priorities

Pullman & Comley, LLC on

Pullman & Comley’s Public Finance tax attorneys are pleased to bring you the latest development on the budget reconciliation front as it relates to municipal bonding. Last Thursday, September 9, 2021, the House Ways and Means...more

Eversheds Sutherland (US) LLP

Warren bill fundamentally changes financial account reporting requirements and substantially increases IRS funding

On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...more

Katten Muchin Rosenman LLP

The Code to the Rescue! Leveraging the Internal Revenue Code to Help Employees During the COVID-19 Crisis

As we find ourselves in the midst of a national medical and financial crisis, employers are asking what they can do to help employees, and how they can do it in a way that costs less money. Although the President just signed...more

Womble Bond Dickinson

How to Make Charitable Contribution Deductions Vanish in to Thin Air – a Review of the Charitable Contribution Substantiation...

Womble Bond Dickinson on

On July 27, 2018, the Treasury issued final regulations regarding substantiation requirements for cash and noncash charitable contributions. T.D. 9836 (2018). The final Regulations reflect amendments to Section 170 of the...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Ballard Spahr LLP

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Ballard Spahr LLP on

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

Orrick, Herrington & Sutcliffe LLP

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Cadwalader, Wickersham & Taft LLP

Proposed QI Agreement Addresses Cascading Withholding on Dividend Equivalents

On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

The Grisly Death of Determination Letters for Individually Designed Plans

The Internal Revenue Service (IRS) announced last year that it would end its staggered five-year remedial amendment cycle system for individually designed retirement plans under the determination letter program due to...more

Baker Donelson

Spotlight On Alabama: A Busy Tax Year in Review

Baker Donelson on

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

Troutman Pepper Locke

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

Troutman Pepper Locke on

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

BakerHostetler

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement

BakerHostetler on

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

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