News & Analysis as of

Revenue Procedures

Missed opportunity - IRS releases narrow guidance for taxpayers seeking to correct accounting methods subsequent to ASC 606...

On May 10, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-29, 2018-21 I.R.B. 1, which provides automatic accounting method change procedures for taxpayers seeking to align methods of income recognition for...more

City’s Electric Utility Fund Transfer to General Fund Upheld by Court - California Appellate Court Interprets Term “Increase” and...

by Best Best & Krieger LLP on

The City of Riverside’s transfer of electric utility service charge revenue to the City’s general fund for general purposes was upheld last week by a California Appellate Court. ...more

IRS releases updated automatic changes in methods of accounting list

On May 10, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-31, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev. Proc. 2017-30, the list...more

Investment Funds Update Europe - Legal and regulatory updates for the funds industry from the key asset management centres and...

by Dechert LLP on

Consultation Paper: amendments to Central Bank UCITS Regulations - The Central Bank published a Consultation Paper (CP 119) on 29 March 2018, proposing amendments to the Central Bank UCITS Regulations and the consolidation...more

An Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

by Foley & Lardner LLP on

In the past few years, the IRS has changed its guidance on whether “management contracts” result in private business use for purposes of the restrictions on use of property financed with tax-exempt bonds. This update...more

IRS Expands Remedial Action Options for Tax-Exempt Bonds

by Miles & Stockbridge P.C. on

On April 11, 2018, the Internal Revenue Service published Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), providing new guidance to issuers on the availability of remedial actions to preserve the status of tax advantaged...more

Much Ado about $50… IRS Announces Relief for Reduction of Maximum HSA Contributions

by Snell & Wilmer on

On April 3, we blogged about a reduction in the HSA contribution limit for family coverage in 2018 from $6,900 to $6,850. This was a technical change resulting from the Tax Cuts and Jobs Act that adjusted the method for...more

I Missed a Tax Election…Now What? Requesting 9100 Relief

What do we, as tax professionals, do when we discover (or our clients discover) that a tax election has been inadvertently missed? There may be a solution for some missed elections. Regulations §§ 301.9100-1 through...more

IRS Transition Relief Reinstates $6,900 Family Limit for 2018 HSAs

On April 26th, the IRS released Rev. Proc. 2018-27, effectively reinstating a $6,900 limit on 2018 health savings account (“HSA”) contributions for family coverage. This is welcome relief for individuals who planned on...more

Taxation of Carried Interests: 2017 Tax Act and Supplemental Guidance

by White and Williams LLP on

The ability of a partnership to grant service providers (typically key management) an interest in a partnership on a non-taxable basis, with potential long-term capital gain treatment on post-grant appreciation, is unique to...more

IRS Provides Issuers Of Tax-Advantaged Debt with New "DIY" Tools to Fix Nonqualified Use

by Bracewell LLP on

On April 11, 2018, the IRS released Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), which provides an expansion of the remedial actions available to issuers of tax-advantaged bonds. Specifically Rev. Proc. 2018-26...more

IRS Expands Remedial Action for Nonqualified Use of Tax-Advantaged Bonds

The IRS on April 11, 2018 released Revenue Procedure 2018-26 (Rev. Proc. 2018-26), which expands remedial action options in connection with certain post-issuance leases to private parties of facilities financed with...more

EO Update: e-News for Charities & Nonprofits

Use Form 1024-A to Apply for Recognition of Exemption under IRC Section 501(c)(4) - Organizations that choose to apply for recognition of exempt status under Internal Revenue Code (IRC) Section 501(a) as an organization...more

Estate Planning Adjustments for Tax Year 2018 & Chained CPI Under New Tax Act

by Williams Mullen on

Many estate planning provisions of the Internal Revenue Code contain brackets, exemptions, exclusions, deductions, or other figures that the Internal Revenue Service adjusts annually for inflation. On December 22, 2017,...more

IRS announces change in 2018 HSA limit for family coverage

On March 5, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-18, which changes the family limit on annual contributions to Health Savings Accounts (HSAs). The Revenue Procedure announced that the HSA limit...more

IRS Reduces 2018 Health Savings Account Limit for Family Coverage

On March 5, 2018, the IRS released Revenue Procedure 2018-18, which, among other things, adjusts downward the 2018 total contribution limit to health savings accounts (HSAs) for individuals enrolled in family coverage. In...more

IRS Reduces 2018 Annual HSA Contribution Limit for Family Coverage

In May 2017, the IRS issued Rev. Proc. 2017-37 announcing the inflation-adjusted health savings account contribution limits for 2018 as $3,450 for self-only coverage and $6,900 for family coverage. However, this week the...more

IRS Clarifies Revenue Procedure 2017-47 Safe Harbor for Inadvertent Normalization Violations

On February 23, 2018, the Internal Revenue Service (IRS) released Generic Legal Advice Memorandum (GLAM) 132120-17, clarifying Revenue Procedure 2017-47.1 This GLAM clarifies that the phrase “in a manner that totally reverses...more

IRS GuideWire

Under Revenue Procedure 2018-15, the IRS generally will not require a new exemption application from a domestic section 501(c) organization that changes its form or place of organization. Rev. Rul. 67-390 and Rev. Rul....more

UK charities seeking opinions on their equivalency to US tax-exempt charities

by DLA Piper on

On 2 October 2017, the IRS provided guidance to US tax advisers for issuing opinions to the effect that a non-US charity is equivalent to an analogous tax-exempt US charity (Rev. Proc. 2017-53, 2017-40 IRB 263). Few non-US...more

What you should know about estate and gift tax 2018 inflation adjustments

by Thompson Coburn LLP on

The IRS has announced the 2018 inflation adjustments for many tax provisions, including exemptions for estate, gift and generation-skipping transfer taxes and the annual exclusion amount for gifts. The 2018 estate and gift...more

Recent Merger Reflects Enhanced Need for Revenue Cycle Management Platforms

Two of the nation’s most noteworthy companies in the Revenue Cycle Management (“RCM”) technology space, Navicure Inc., and ZirMed Inc., announced a merger on September 14, 2017....more

IRS Opens Pilot Program on Tax-free Spin-offs

by Jones Day on

The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more

IRS Expands Scope of Spin-Off Private Letter Rulings in 18-Month Pilot Program

by Shearman & Sterling LLP on

On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more

IRS Provides Safe Harbor for Inadvertent Normalization Violations

On September 7, 2017, the IRS issued Revenue Procedure 2017-47, which provides a safe harbor for regulated public utilities for inadvertent or unintentional uses of a practice or procedure that is inconsistent with the...more

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