News & Analysis as of

Reporting Requirements Internal Revenue Service Internal Revenue Code (IRC)

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

Rivkin Radler LLP on

You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Fox Rothschild LLP

FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split

Fox Rothschild LLP on

For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more

Holland & Knight LLP

IRS Releases Long-Awaited Section 45Q LCA Procedures

Holland & Knight LLP on

The IRS on July 24, 2024, released Notice 2024-60, which provides Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses the information that must be included in the required life...more

Cadwalader, Wickersham & Taft LLP

Finally Final Crypto Reporting Regulations

On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Mayer Brown

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

Mayer Brown on

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

Blank Rome LLP

Updated Reporting Requirements for Foreign Gifts and Foreign Trusts

Blank Rome LLP on

Proposed Treasury Regulations (the “Proposed Regulations”) have recently been issued to update and clarify existing reporting obligations for U.S. persons who receive gifts from abroad or who are owners or beneficiaries of...more

Holland & Hart - Employers' Lawyers

IRS Issues Final Prevailing Wage and Apprenticeship Regulations

On June 25, 2024, the Internal Revenue Service and U.S. Department of Treasury published final Treasury Regulations (“Final Regulations”) in the Federal Register on the prevailing wage and registered apprenticeship...more

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

Fox Rothschild LLP on

The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

Seward & Kissel LLP

New IRS Tax Form for Digital Asset Broker Reporting

Seward & Kissel LLP on

The IRS released a draft of a new tax form, Form 1099-DA, that brokers will use to report proceeds from certain digital asset transactions. The draft Form 1099-DA can be found on the IRS website and below. The effective date...more

Dickinson Wright

The Top Affordable Care Act Reporting Mistakes We Continue to See in 2024

Dickinson Wright on

Nearly once a week, I receive a frantic call or email from a current or potential client who has received a proposed or final assessment from the IRS related to Affordable Care Act (“ACA”) reporting. So-called “Applicable...more

Nelson Mullins Riley & Scarborough LLP

Death, Taxes, and Crypto Reporting – The Three Things You Cannot Escape

The IRS released a draft of Form 1099-DA “Digital Asset Proceeds from Broker Transactions” in April which will require anyone defined as a “broker” to report certain information related to the sale of digital assets. The new...more

Eversheds Sutherland (US) LLP

Government updates procedures to change R&D, income recognition, and inventory methods in new Rev. Proc. 2024-23

On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Ballard Spahr LLP

IRS Unveils Broad Draft Information Reporting Form for Digital Asset Transactions

Ballard Spahr LLP on

On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more

Troutman Pepper

Preparing for IRS Cash Transaction Reporting in the Cannabis Industry

Troutman Pepper on

The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more

Fox Rothschild LLP

IRS Issues New Guidance for Cannabis Companies That Receive Over $10K in Cash

Fox Rothschild LLP on

The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Sherman & Howard L.L.C.

FinCEN Implies Certain Tax-Exempt Entities Are Subject to the CTA (They’re Not)

As companies across the nation grapple with the reality of complying with the Corporate Transparency Act (CTA), which went into effect on January 1 of this year, certain nonprofits that expected to be exempt from such toils...more

Littler

IRS Updates FAQs on 1099-Ks Used for Gig Workers and Others

Littler on

The IRS recently updated its guidance for completing Form 1099-K, used primarily by “gig” companies providing compensation using payment apps or online marketplaces and for individuals selling goods on online marketplaces...more

Cadwalader, Wickersham & Taft LLP

ABA Tax Section Comments on Proposed Crypto Broker Reporting Regulations

On December 20th, 2023, the American Bar Association Tax Section published detailed comments and recommendations (the “ABA Comments”) on the proposed crypto broker reporting regulations.  As discussed here, the New York State...more

Cooley LLP

Transitional Tax Reporting Guidance for Business Transactions Involving Digital Assets

Cooley LLP on

In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more

Cadwalader, Wickersham & Taft LLP

Treasury Cries “Uncle” to Crypto Industry: Crypto Reporting Delayed

On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year.  Persons engaged in...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Verrill

Safe Harbor Exception for De Minimis Dollar Amount Reporting Errors

Verrill on

As part of the routine administration of employee benefit plans, shortly after the end of a calendar year, many transactions must be reported to the federal government (“information returns”) and participants (“payee...more

160 Results
 / 
View per page
Page: of 7

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide