News & Analysis as of

U.S. Treasury Internal Revenue Code (IRC) Withholding Tax

The Wagner Law Group

IRS Issues Final Regulations on Non-U.S. Tax Withholding Under Deferred Compensation Plans, IRAs and Commercial Annuities

The Wagner Law Group on

The Internal Revenue Service (“IRS”) and the Treasury Department on October 21, 2024, issued final regulations under Sections 3405(a) and 3405(b) of the Internal Revenue Code of 1986, as amended (“Code”). (The IRS had issued...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Troutman Pepper Locke

Treasury Department Proposes to Clarify That On-Demand Pay and Earned Wage Access Programs Are Not Loans

Troutman Pepper Locke on

In its annual General Explanations of the Administration’s Revenue Proposals, the U.S. Department of Treasury proposed clarifications and amendments to the Internal Revenue Code to address on-demand pay arrangements (also...more

McDermott Will & Emery

New Attribution Requirement Denies Foreign Tax Credits For Certain Withholding Taxes (And Other Taxes)

McDermott Will & Emery on

On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more

Foster Garvey PC

Potential Payroll Tax Deferral Is Available – Employers Must Understand the Program and Use Extreme Caution Before Blindly Jumping...

Foster Garvey PC on

On August 8, 2020, President Trump issued an executive order, directing the U.S. Treasury to grant employers the ability to defer the withholding, deposit and payment of certain payroll taxes as further COVID-19 tax relief....more

McDermott Will & Emery

Weekly IRS Roundup May 25 – May 29, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 25 – May 29, 2020... May 26, 2020: The IRS and United States Department of the Treasury...more

McDermott Will & Emery

Weekly IRS Roundup February 10 – 14, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Morgan Lewis

IRS Issues Withholding Guidance on Transfers of Non-Publicly Traded Partnership Interests by Non-US Persons

Morgan Lewis on

The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

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