News & Analysis as of

Internal Revenue Service U.S. Treasury

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.  

Tax Reform and Tax-Exempt Bonds: Risks Presented by the Tax Cuts and Jobs Act

by Foley & Lardner LLP on

On November 2, 2017, the “Tax Cuts and Jobs Act” was introduced in the House of Representatives. This act has immediate and far-reaching implications for tax-exempt finance. Among other things, the Tax Cuts and Jobs Act...more

Treasury Withdraws Problematic Section 2704 Discount Regulation

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. In early October, Treasury announced that it proposed to repeal or revise these regulations. ...more

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

by Shearman & Sterling LLP on

On September 29, 2017, the United States District Court for the Western District of Texas granted summary judgment in favor of the U.S. Chamber of Commerce and Texas Association of Business, holding that the Internal Revenue...more

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

by Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

IRS Proposes Update and Streamlining of Public Approval Under TEFRA

by Miles & Stockbridge P.C. on

The Internal Revenue Service (the “IRS”) and The U.S. Department of the Treasury (the “Treasury”) proposed regulations on September 28, 2017 to update and streamline the public approval requirement applicable to tax-exempt...more

Treasury Would Overhaul 2016 Regulatory Guidance

by Alston & Bird on

With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more

IRS and Treasury Department to Withdraw Proposed Tax Regulations Curbing Valuation Discounts

by Davis Wright Tremaine LLP on

In a positive development for closely-held business owners and their families, the Treasury Department recently recommended the complete withdrawal of its proposed tax regulations that would have severely limited the...more

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

Treasury Report Proposes Substantial Revisions to Controversial Tax Regulations

by Morrison & Foerster LLP on

Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more

Treasury Hints That Regulatory Review May Target FATCA Regulations

by Fox Rothschild LLP on

In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of...more

No Comment: Temporary Anti-Inversion Regulation Rejected Under Administrative Procedure Act

On Friday, September 29, 2017, the Federal court for the Western District of Texas struck down the temporary anti-inversion regulation issued under Sec. 7874, which has been charged with preventing the planned $160 billion...more

Withdrawal of Proposed Tax Regulations Affecting Availability of Valuation Discounts to Family Business Owners

In September and December of last year, we posted blog articles discussing the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704 proposed...more

Treasury Withdraws Proposed Regulations Aimed at Minimizing Valuation Discounts

by McDermott Will & Emery on

Proposed section 2704 regulations were withdrawn in regulatory review ordered by President Trump....more

Proposed Section 2704 Regulations to be Withdrawn

by Butler Snow LLP on

Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more

Ding, Dong, the Witch is Dead

by Charles (Chuck) Rubin on

--Here lies the remains of the Code §2704 Proposed Regulations. RIP, 2016-2017-- As part of President Trump’s mandated review of federal regulations, the Secretary of Treasury has issued a report specifically recommending...more

IRS and Treasury Department Announce Withdrawal of Proposed 2704 Regulations

by Tucker Arensberg, P.C. on

On October 4, 2017, in its Second Report to the President Identifying and Reducing Tax Regulatory Burdens the U.S. Department of the Treasury announced that it is recommending the complete withdrawal of the proposed 2704...more

Treasury Plans to Pull Unpopular Discount Regulation

As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Potential Help for Cash-Strapped RICs and REITs - Tax Update Volume 2017, Issue 5

by Pepper Hamilton LLP on

Recently, the IRS provided a method for publicly offered real estate investment trusts (REITs) and publicly offered registered investment companies (RICs) to fulfill their distribution requirements while distributing stock as...more

Treasury To Repeal/Revise 8 Burdensome Regs

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

Treasury Plans to Pull Unpopular Discount Regulation

As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Wealth Management Update - September 2017

by Proskauer Rose LLP on

September Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The September § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Notice 2017-42 Provides for One-Year Extension of Existing Section 871(m) Rules

by Shearman & Sterling LLP on

On August 4, 2017, the Treasury Department and the Internal Revenue Service (the “IRS”) issued Notice 2017-42 (the “New Notice”) providing taxpayers with relief from certain aspects of the final and temporary regulations...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

by Latham & Watkins LLP on

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

One-Year Delay to the Application of Section 385 Documentation Rules

by Shearman & Sterling LLP on

On July 28, 2017, the Treasury Department and the IRS announced in Notice 2017-36 (the “Notice”) that they will delay the documentation rules of Treasury regulation section 1.385-2 to debt instruments issued or deemed to be...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

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