News & Analysis as of

Protecting Americans from Tax Hikes (PATH) Act

The GOP’s Tax Cuts and Jobs Act Includes Changes Impacting the Renewable Energy Industry

by Foley & Lardner LLP on

On November 3rd, House Ways and Means Committee Chairman Kevin Brady (R. Tex.) released the “chairman’s mark” to H.R. 1, the “Tax Cuts and Jobs Act” (TCJA). The TCJA represents the most extensive rewrite of the Internal...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

February 2017: Client Alert

by Moskowitz LLP on

Tax Calendar - February 28 - Payers must file informational returns with the IRS. (Except certain Forms 1099-MISC with non-employee compensation payments in box 7, which are due before February 1. Excluding...more

The TTB Proposes New Definition of Hard Cider

by McDermott Will & Emery on

On January 23, 2017 the Alcohol & Tobacco Tax & Trade Bureau (TTB) published a Temporary Rule and a Notice of Proposed Rulemaking (NPRM) related to the new definition of hard cider. Congressional action required a new...more

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

by Proskauer - Tax Talks on

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Boozelaw: TTB Adopts Changes Designed to Benefit Startup Brewers, Winemakers and Distillers

by Varnum LLP on

For certain brewers, wine makers and distillers, the gift-giving season did not necessarily end in December. The Alcohol and Tobacco Tax and Trade Bureau (TTB) recently announced it has adopted changes that may impact the tax...more

TTB Modified Tax Filing Timeframe for Some Taxpayers

by McDermott Will & Emery on

On January 4, 2017 TTB published in the Federal Register a temporary rule, T.D. TTB–146, modifying the tax filing timeframe for taxpayers who fall below a certain monetary threshold and removing the bond requirements for...more

TTB Changes Under the Fall Edition of the Unified Agenda

by McDermott Will & Emery on

On December 23rd, 2016 the federal government published its Fall edition of the “Unified Agenda” – a bi-annual compilation of all ongoing federal rulemaking projects. Attached is a copy of the TTB detail from this latest...more

IRS Issues Additional Guidance on Beginning of Construction Rules for Renewable Projects

by McDermott Will & Emery on

On December 15, 2016, the Internal Revenue Service released Notice 2017-04, which provides welcome guidance on how to meet the “beginning of construction” requirements for wind and other qualified facilities. There has been...more

IRS Extends Continuity Safe Harbor Until December 31, 2018

On December 15, 2016, the US Internal Revenue Service (the “IRS”) released Notice 2017-4 (the “Notice”), which updates previous IRS “start of construction” guidance by extending the Continuity Safe Harbor to December 31,...more

2016 Year-End Estate Planning Advisory

by Katten Muchin Rosenman LLP on

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

2016 Proskauer Annual Review and Outlook for Hedge Funds, Private Equity Funds and Other Private Funds

by Proskauer Rose LLP on

This special report provides a summary of some of the significant changes and developments that occurred in the past year in the private equity and hedge funds space, as well as certain recommended practices that investment...more

Payroll Get Ready — Employers Face New January 31st Filing Deadline for W-2 and 1099-MISC Forms

by McDermott Will & Emery on

In Depth - Beginning with W-2 forms filed with respect to 2016 wages, a new law requires employers to file the government copy by January 31, 2017, for both paper and electronic copies. The accelerated deadline also...more

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Tax-Exempt Organizations Update: Selected Developments From Washington

by McGuireWoods LLP on

Although comprehensive tax reform in 2016 is unlikely in the midst of an election year, so far in 2016, parties on all sides have proposed specific changes to the rules applicable to exempt organizations. Lawmakers in...more

September 6, 2016 Deadline: New IRS Notice Requirement for 501(c)(4) Organizations

by Hodgson Russ LLP on

Nonprofit entities that intend to operate as 501(c)(4) organizations, such as social welfare organizations, are subject to a new notice requirement with the Internal Revenue Service (IRS) as a result of the Protecting...more

IRS to Invalidate Unused ITINs Unless Renewed

by Holland & Knight LLP on

The Internal Revenue Service (IRS) is requiring individuals with inactive or old individual taxpayer identification numbers (ITINs) to renew their ITINs. The renewals impact individuals who received ITINs prior to 2013. The...more

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Remembering Four Years Ago, Will Tax Reform Come out of This Lame Duck Session of Congress?

No matter who wins the White House in November, the new president’s agenda will include tax reform. But changes to our tax laws need not wait until after inauguration day, as we learned four years ago when the “fiscal cliff”...more

New IRS notification process announced for 501(c)(4) nonprofits

by Dentons on

Earlier this month, the US Internal Revenue Service (IRS) released its long-awaited temporary regulatory framework implementing the new statutory notification requirements placed on 501(c)(4) nonprofit organizations by the...more

New Electronic Form 8976 to Alert IRS About Section 501(c)(4) Status; 1023-EZ Application Reduced to $275

The Protecting Americans from Tax Hikes (“PATH”) Act of 2015, enacted in December 2015, requires organizations to notify the IRS if they desire to operate under Section 501(c)(4) of the Internal Revenue Code (“Code”). (Only...more

IRS Announces 501(c)(4) Notification Process

by Clark Hill PLC on

The Internal Revenue Service ("IRS") has issued temporary regulations explaining how organizations exempt under Section 501(c)(4) of the Internal Revenue Code must provide notice to the Service within 60 days of...more

PATH Act 501(c)(4) Matters Update #2: Notification Requirement Clarified; Temporary Regulations and Notification Form Issued

As specified in Notice 2016-09 (discussed in our recent blog post on the PATH Act), the IRS has issued temporary regulations describing new notification procedures and a notification form for certain (current and prospective)...more

New IRS Notification Requirement for Certain 501(c)(4)s

by Perkins Coie on

The IRS published temporary proposed regulations on July 12, 2016 that will impact all 501(c)(4) social welfare organizations formed after July 8, 2016. The proposed regulations will also impact many existing 501(c)(4)...more

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