Blakes Continuity Podcast: COVID-19: The Regulatory Impact on Pensions
Viewpoints: Portfolio Company Pension Liabilities
JONES DAY TALKS®: ESG: The Opportunities and the Risks
Non-U.S. investors are generally subject to U.S. federal income tax on gains from investments in private U.S. real estate investment trusts (REITs). Two exceptions (among others) are for investments in “domestically...more
On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more
At the end of 2022, the Department of the Treasury and the Internal Revenue Service (together, the “IRS”) issued two sets of guidance – a final rule and a proposed rule – addressing the application of certain provisions of...more
As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022- In 2022 we...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more
This chart sets forth some of the annually adjusted dollar limits that impact employee benefits, as published by the Internal Revenue Service, the Social Security Administration and the Pension Benefit Guaranty Corporation. ...more
The Internal Revenue Service has announced the first installment of its annual “Dirty Dozen” list of tax scams. Published every year, the “Dirty Dozen” comprises the twelve most prevalent tax scams that taxpayers may...more
Over the years, tax shelter ideas have occasionally arisen in connection with the interpretation of some of the pension provisions found in US tax treaties, encouraged, perhaps, by the lack of guidance on many treaty...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 14, 2021 – June 18, 2021... June 14, 2021: The IRS issued a news release unveiling updates...more
Payroll Tax Relief Under CARES Act, FFCRA, and Executive Order - While the Coronavirus Aid, Relief, and Economic Security (CARES) Act permitted employers to defer depositing the portion of the FICA taxes the employer pays...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more
New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
Corporate entities under common control are generally treated as a single employer for purposes of applying the core rules that govern employee benefit plans and executive compensation arrangements. For that reason, a...more
Editor's Overview - Welcome once again to Proskauer's newly revamped ERISA Newsletter. As a reminder, readers can obtain the information in this Newsletter as it is published on our blog. Our featured article this...more
Near the end of 2016, the US Department of Treasury and the Internal Revenue Service published two significant sets of proposed regulations on issues pertaining to defined benefit pension plans, including mortality table...more
Substantiation Requirement Clarified for Examination Purposes - Over the past few years, employers and plan administrators have frequently asked how hardship withdrawal requests can/should be substantiated from 401(k)...more
The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S....more
As described in a prior alert, the IRS issued Notice 2015-49, which abruptly announces the IRS’s intention to prohibit lump-sum cashout windows for pension plan retirees already in pay status. The IRS intends to prohibit...more