Background - Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more
Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved. The U.S. Internal Revenue Service has released proposed regulations clarifying when fines, penalties, and...more
On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more
Tax Reform Slashes Deductions for Settlements Paid to Government Agencies for Violations and Investigations - IRS Requests Comments by May 18 - Businesses making payments to governments and governmental entities on or after...more
Effective immediately, a settlement agreement or a judgment with the government must set forth the specific amount of restitution, remediation of property, or monies paid to come into compliance with any law violated, for...more
The Internal Revenue Service has issued Notice 2018-23 (dated March 27, 2018) to implement transitional guidance for application of new IRC secs. 162(f) and 6050X. As described in our previous Client Advisory, those new tax...more
A minor provision concerning deductibility in Public Law 115-97, commonly known as the Tax Cuts and Jobs Act (Act), may have significant impacts on administrative and judicial settlements between companies and the U.S....more
March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
The new tax law changed the deductibility of settlements with government agencies in some circumstances thereby increasing the cost to companies to settle these cases. The deduction arose from the section in the Internal...more