News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Settlement

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

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Miller Canfield

IRS Fast-Track Settlement Has Been Refined to Improve Accessibility

Miller Canfield on

Taxpayers whose tax returns the IRS examines may experience long administrative delays in working with the IRS to resolve unagreed issues. About twenty years ago, the IRS developed a procedure – fast track settlement – to...more

DarrowEverett LLP

The Tax Implications of Divorce: Alimony, Child Support, IRAs and More

DarrowEverett LLP on

Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and...more

Freeman Law

Are Lawsuit or Settlement Damages Taxable?

Freeman Law on

Taxpayers who suffer from physical injuries or physical sickness can generally take advantage of a special provision in the Code that makes such damages non-taxable. See I.R.C. § 104(a)(2). Generally, this can be an easy...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations Address Disallowance of Deductions for Fines, Penalties and Other Amounts

On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more

Cozen O'Connor

November 13, 2018 Deadline Approaching For Comments On IRS Rules Relating To Reporting And Tax Deductions Of State AG Settlements

Cozen O'Connor on

The process of ironing out settlements of state attorney general (“AG”) investigations and litigations is likely to get more complicated. The 2017 Tax Cuts and Jobs Act (“Act”), among the many other things it did, amended a...more

Eversheds Sutherland (US) LLP

IRS rules that a method of reflecting a federal income tax settlement in ratemaking violated the consistency rule of normalization

In PLR 201828010, the Internal Revenue Service (IRS) considered the proper ratemaking treatment for reflecting the results of a federal income tax settlement. The taxpayer was a member of an affiliated group filing...more

Best Best & Krieger LLP

Best in Law: Tax Ruling Confirms Protocol on Job-Related Judgments

The California Court of Appeal recently confirmed that employment-related settlements or judgments are wages from which employers must withhold payroll taxes. In Cifuentes v. Costco Wholesale Corp., Cifuentes...more

Littler

California Appellate Court Holds Employer Must Withhold Taxes on Back Pay

Littler on

On June 26, 2015, a California appellate court rendered a precedential opinion that should hopefully put to rest the issue of whether an employer must withhold taxes on settlements or judgments made to former employees in...more

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