News & Analysis as of

Internal Revenue Service Memorandum of Guidance

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.  
McDermott Will & Emery

Weekly IRS Roundup August 24 – August 28, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020... August 24 2020: The IRS published a memorandum concerning...more

McDermott Will & Emery

Weekly IRS Roundup August 17 – August 21, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...more

Fisher Phillips

Documentation Relief For Hardship Distributions

Fisher Phillips on

Retirement plans are permitted, but not required, to provide in-service distributions of elective deferrals to participants if they can show financial hardship, which is defined as a hardship that is “deemed to be on account...more

Sherman & Howard L.L.C.

IRS Issues a Memorandum on Substantiation Guidelines for Safe-Harbor Hardship Withdrawals from 401(k) Plans

On February 23, 2017, the Internal Revenue Service (“IRS”) issued a Memorandum to IRS agents. The Memorandum identified the steps agents should take, in examining a 401(k) plan, to confirm that a hardship withdrawal is...more

BCLP

New IRS Memo Confirms Tax Treatment of Wellness Programs & Incentives

BCLP on

In a recently released IRS Chief Counsel Memo, the IRS confirmed that wellness incentives are generally taxable. The memo also, indirectly, confirmed the tax treatment of wellness programs more generally....more

Bradley Arant Boult Cummings LLP

Wellness Rewards Included in Employee’s Income

The Internal Revenue Service (IRS), through its Office of Chief Counsel, recently released a memorandum regarding the tax treatment of wellness programs. Although the memorandum is not formal advice that may be relied on, it...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Solar Tax Equity Memo Stating the Obvious

On Friday, the IRS issued a heavily redacted Chief Counsel Advice (CCA) memorandum, which addresses the intersection of solar investment tax credit partnership flip transactions and the wind production tax credit partnership...more

Miller & Martin PLLC

Does Your Retention Bonus Plan Violate IRS Code?

Miller & Martin PLLC on

In a memorandum released earlier this month, the IRS Office of Chief Counsel ruled that a retention bonus payable to an executive violated Section 409A of the Internal Revenue Code ("409A"). The IRS further ruled that the...more

Proskauer - Employee Benefits & Executive...

IRS Chief Counsel Memorandum Clarifies that Correction of Section 409A Failures in Year of Vesting Will Not Shield Income...

Earlier this month, the Office of Chief Counsel of the Internal Revenue Service released a Memorandum clarifying the impact of a correction of a Code Section 409A operational failure before the date of vesting of nonqualified...more

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