News & Analysis as of

Tax Planning Proposed Regulation

McDermott Will & Emery

Weekly IRS Roundup May 20 – May 24, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup April 1 – April 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024....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

Cadwalader, Wickersham & Taft LLP

IRS Releases Proposed Donor-Advised Fund Regulations

The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and...more

McDermott Will & Emery

Weekly IRS Roundup February 19 – February 23, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 19, 2024 – February 23, 2024. February 20, 2024: The IRS published Announcement 2024-12, which...more

McGuireWoods LLP

Donor Advised Funds: Proposed Regs Offer Guidance, But Leave Big Questions Unanswered

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For the past 16 years, the U.S. Department of the Treasury’s Office of Tax Policy and the Internal Revenue Service’s joint Priority Guidance Plan has included the issuance of regulations relating to donor advised funds (DAFs)...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

McDermott Will & Emery

Weekly IRS Roundup December 25 – December 29, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 25, 2023 – December 29, 2023...more

Farella Braun + Martel LLP

The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In today's episode, the final episode on the new DAF regulations, Cynthia Rowland takes a close look at the new Proposed Regulations 53.4966-2 and -5, which cover the...more

McDermott Will & Emery

Weekly IRS Roundup December 11 – December 15, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 11, 2023 – December 15, 2023. ...more

Akin Gump Strauss Hauer & Feld LLP

Clean Vehicle Tax Credit – Foreign Entity of Concern Rules Proposed

On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

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Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more

McDermott Will & Emery

Weekly IRS Roundup November 20 – November 24, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 20, 2023 – November 24, 2023....more

McDermott Will & Emery

Weekly IRS Roundup November 13 – November 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more

McDermott Will & Emery

Weekly IRS Roundup August 14 – August 18, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 14, 2023 – August 18, 2023...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Would Affect the Taxation of US Real Estate for Foreign Investors

On December 28, 2022, the Treasury Department released a set of proposed regulations that, if finalized, would alter key rules affecting many real estate funds, sovereign wealth funds and other foreign investors in U.S. real...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Freeman Law

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

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Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning - On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

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Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

Tucker Arensberg, P.C.

Gifting and Estate Tax in Period of Big Changes

Tucker Arensberg, P.C. on

​​​​​​​The Tax Cuts and Jobs Act of 2017 increased the federal estate and gift tax exclusion amount (sometimes called the “basic exclusion amount” or “BEA”) from $5 million to $10 million. (Those numbers are adjusted for...more

Stark & Stark

[Webinar] The Administration’s 2022 Proposed Estate and Gift Tax Changes - June 21st, 6:00 pm - 6:45 pm ET

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Join Robert F. Morris, Esq., to discuss some important components of the Administration’s proposed changes to Federal Estate and Gift Taxes. The discussion will include how these changes may impact you and your estate plan....more

Stark & Stark

[Webinar] The Administration’s 2022 Proposed Estate and Gift Tax Changes - June 21st, 12:00 pm - 1:45 pm ET

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Join Robert F. Morris, Esq., to discuss some important components of the Administration’s proposed changes to Federal Estate and Gift Taxes. The discussion will include how these changes may impact you and your estate plan....more

Davis Wright Tremaine LLP

Not So Fast! IRS Releases Proposed Clawback Regulations

The IRS recently released proposed clawback regulations on the treatment of gifts that are complete at the time of transfer but are potentially included in the donor's gross estate at death. Such gifts will likely get the...more

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