There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more
The sweeping changes made by the legislation commonly known as the One, Big, Beautiful Bill Act (OBBBA) included permanent 100% first year bonus depreciation for qualified property acquired and placed in service after January...more
On December 15, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service published final regulations (the “Final Regulations”) under Section 892,1 which contains the tax exemption for foreign...more
On December 15, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service published new proposed regulations (the “Proposed Regulations”) under Section 8921, which contains the tax exemption for...more
On December 12, the Treasury Department issued final Treasury Regulations (the “Final Regulations”) and proposed Treasury Regulations (the “Proposed Regulations”) that address various issues under Section 892 of the Internal...more
On December 19, 2025, Treasury and the IRS released Notice 2026-1 (the “Notice”) establishing an alternative method for taxpayers to substantiate carbon oxide sequestration volumes for section 45Q carbon capture tax credits...more
On December 12, 2025, the United States Department of the Treasury (“Treasury”) and the Internal Revenue Service released final regulations (the “Final Regulations”) under Section 892 of the Internal Revenue Code of 1986, as...more
On December 12, 2025, Treasury released final regulations (the Final Regulations), as well as proposed regulations (the Proposed Regulations), relating to the Section 892 tax exemption for certain income of foreign...more
On December 15, 2025, the United States Department of the Treasury and the Internal Revenue Service (IRS) published final and proposed regulations under Section 892 of the Internal Revenue Code. The final regulations are...more
On Dec. 12, the Treasury Department and the IRS issued final regulations (the Final Regulations) relating to the taxation of income of foreign governments from investments in the United States under Section 892 of the U.S....more
The U.S. government has issued final regulations significantly limiting the situations where a corporation will be liable for the 1% corporate stock buyback tax applicable to public companies. The Situation: Taxpayers...more
The law concerning federal limits on political advocacy by nonprofit organizations continues to evolve. For Section 501(c)(4) social welfare organizations, two federal court decisions, issued nearly a year apart, have...more
On October 21, 2025, the Senate Committee on Banking, Housing, and Urban Affairs introduced S.B. 3017, titled the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act...more
On October 20, 2025, the Treasury and the IRS released proposed regulations (REG‑109742‑25 (the “Proposed Regulations”)) that would remove the “foreign‑controlled domestic corporation” look‑through rule previously included in...more
Many 401(k) plan sponsors are currently discussing implementation of the new Roth catch-up contribution rules, which were published on September 16, 2025, with their third-party plan administrators, payroll vendors, and...more
The Treasury Department recently released its Spring Regulatory Agenda, which contains several important retirement, health, and executive compensation initiatives for this year....more
As we have previously reported, the “One Big Beautiful Bill Act” (OBBBA) provides an above-the-line tax deduction for certain “qualified tips.” To qualify for the deduction, the tips must (among other conditions) be “cash...more
In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law, significantly revising the U.S. tax code to reflect the Administration’s domestic energy, trade, and national security priorities. Among...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
This Freeman Law Insights blog dives into what is a minister of the gospel for housing allowance and federal income tax purposes. Housing Allowances, Generally. Compensation for services rendered is generally...more
Proposed Treasury regulations relating to catch-up contributions were issued in January of 2025 that include guidance for the mandatory Roth catch-up requirement, which was first provided under section 603 of Division T of...more
Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more
This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more
Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more