News & Analysis as of

Section 162(f) Tax Cuts and Jobs Act

Troutman Pepper

Final Section 162(f) Regulations Set Forth Deductibility Rules for Payments Involving Government Investigations

Troutman Pepper on

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

Eversheds Sutherland (US) LLP

State of play: A May methods update 

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

Skadden, Arps, Slate, Meagher & Flom LLP

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

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

Jones Day

Deductibility of Fines and Penalties: New Guidance Leaves Key Questions Unanswered

Jones Day on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Highlights From the Recently Issued Proposed Regulations Under Sections 162(f) and 6050X

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

K&L Gates LLP

Another Kind of Tax Cut: Tax Reform Slashes Deductions for Settlements Paid to Government Agencies for Violations and...

K&L Gates LLP on

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

Foley & Lardner LLP

IRS Issues Transitional Guidance Regarding the New "Restitution" Tax Deduction That Affects False Claimes Act and Other Government...

Foley & Lardner LLP on

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

Kelley Drye & Warren LLP

Update: Tax Planning Alert - Amounts Paid at Direction of Government or Specified Non-Government Entities - New IRC sec. 162(f)

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

BakerHostetler

New Tax Law Will Shape Future Environmental Settlements

BakerHostetler on

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

Proskauer Rose LLP

Wealth Management Update - March 2018

Proskauer Rose LLP on

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

Foley & Lardner LLP

New Tax Law Changes Deductibility of Government Settlement Payments in False Claims Act, SEC, FINRA, and Other Types of Cases

Foley & Lardner LLP on

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

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