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Tannenbaum Helpern Syracuse & Hirschtritt LLP

Beyond Estate Planning – Why Divorce Attorneys Need to Know About IRC § 2516

During most divorce proceedings, the legal focus tends to center on important topics such as child custody, spousal support, and the equitable distribution of marital assets....more

McDermott Will & Schulte

IRS roundup: October 23 – November 6, 2025

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 23, 2025 – November 6, 2025. ...more

Allen Barron, Inc.

Is the Burden of Proof on the IRS During an Audit?

Allen Barron, Inc. on

Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS....more

Hone Maxwell

I haven’t filed my taxes or international reports, now what? It might be the best time to ask

Hone Maxwell on

Did you just find out that as a dual citizen you have to report U.S. taxes even if you live abroad? Did you just discover you needed an FBAR, Form 5471, GILTI calculation, Form 3520, Form 5472, or other foreign reporting?...more

McDermott Will & Schulte

IRS roundup: October 7 – October 23, 2025

McDermott Will & Schulte on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025. October 7, 2025: The IRS issued Notice 2025-55, providing guidance on relief from...more

Foley & Lardner LLP

IRS Now Permitted to Share Tax Identification Data with ICE: Considerations for Employers

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On April 7, 2025, the Internal Revenue Service (“IRS”) and the U.S. Immigration and Customs Enforcement (“ICE”) entered into a Memorandum of Understanding (the “MOU”) enabling ICE to request and receive taxpayer identity...more

Rivkin Radler LLP

Visiting the Sins of the Tax Preparer Upon the Taxpayer? The Fraud Exception to the Limitations Period on Assessment

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As we discussed a few weeks ago, the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may...more

Allen Barron, Inc.

Managing an IRS Correspondence Audit

Allen Barron, Inc. on

One of the new realities for U.S. taxpayers includes the responsibility for managing an IRS correspondence audit. What should you do if you are contacted regarding any form of IRS audit? Did you know the present majority of...more

Foley Hoag LLP

Navigating IRC Section 280E: Current Updates for Cannabis Taxpayers

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With October’s deadline for taxpayers on tax return filing extension for tax year 2024 quickly approaching, this alert provides updates to our post in May on the exploding trend of cannabis tax filers taking the uncertain tax...more

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Fisher Phillips

How Will Non-Profits Be Impacted by the Big Beautiful Bill? Your Guide to Key Changes Affecting Charitable Giving, Excise Taxes,...

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President Donald Trump signed a massive budget bill last month – the “One Big Beautiful Bill Act” (OBBBA) – and it significantly impacts non-profits and tax-exempt organizations. While some of the new changes may be...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Cooley LLP

The ‘One Big Beautiful Bill Act’ Permits Immediate Deduction of Domestic R&E Expenditures, in Some Cases Retroactively

Cooley LLP on

On July 4, the “One Big Beautiful Bill Act” (OBBBA) was signed into law, which includes provisions restoring immediate deduction of domestic research and experimentation (R&E) expenditures in tax years beginning after...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Foster Swift Collins & Smith

One Big Beautiful Bill Summary: Notable Tax Code Changes

With the passage of the One Big Beautiful Bill (OBBB), below is a summary of notable changes to the tax code for businesses, as well as an outline of notable changes for individuals....more

Foster Swift Collins & Smith

TEO Tax Update: New Credit for SGO Contributions

Introduction The One Big Beautiful Bill Act (Act) establishes a new federal tax credit for individual donations to Scholarship Granting Organizations (SGOs) serving U.S. elementary and secondary school students....more

Fox Rothschild LLP

The IRS-ICE Tax Data Sharing Agreement: Practical Considerations

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The IRS and ICE have signed a Memorandum of Understanding (MOU) that allows the IRS to share taxpayer information such as names, addresses, and tax data, with ICE for immigration-related criminal enforcement of individuals...more

Rivkin Radler LLP

Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?

Rivkin Radler LLP on

The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more

Morgan Lewis

New Section 174A Restores Domestic R&E Deductibility, but Other Changes Bring Mixed Results

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President Donald Trump signed into law the One Big Beautiful Bill Act on July 4, 2025. Among many other provisions, this bill permits taxpayers to deduct domestic research and experimentation (R&E) expenditures under new...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part I – The SALT Deduction

Foster Garvey PC on

On July 1, 2025, the One Big Beautiful Bill Act, H.R.1 – 199th Congress (2025-2026) (the “Act”) was passed in the U.S. Senate (“Senate”). On July 3, 2025, it was passed in the U.S. House of Representatives (“House”) and...more

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

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The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

McDermott Will & Schulte

Potential Refund Opportunity for Interest and Penalty Amounts Accrued During COVID-19 Federally Declared Disaster

Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...more

Freeman Law

Penalties for Failures with Respect to Forms 1099 and Other Information Returns

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Section 6721 of the Internal Revenue Code imposes a penalty on any person who fails to file a Form 1099 or other information return to the IRS by the required filing date, fails to include all information required to be shown...more

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