News & Analysis as of

Income Taxes Internal Revenue Code (IRC) Excise Tax

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 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 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

DarrowEverett LLP

IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm

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In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more

McGuireWoods LLP

Reminder: Private Foundations Are Subject to 1.39% Excise Tax on Net Investment Income

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With the extended 990-PF filing deadline approaching for private foundations on a calendar year accounting period, foundation leaders should ensure that they have paid the 1.39% net investment income excise tax and should...more

McDermott Will & Emery

Weekly IRS Roundup January 17 – January 20, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more

Groom Law Group, Chartered

IRS Guidance on Excise Tax on Buybacks Clarifies Some Benefits Issues

New Section 4501 of the Internal Revenue Code imposes a 1% excise tax on certain corporate stock repurchases or “corporate buybacks” in excess of $1 million in the taxable year.  The new tax is imposed on the fair market...more

Morgan Lewis

Successful Oil Excise Tax Challenge Leads to Opportunities and Uncertainty for Exporters

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A recent challenge to the constitutionality of the federal excise tax on domestic crude oil exported from the United States proved successful in the US Court of Appeals for the Fifth Circuit. While the US Department of...more

Freeman Law

IRS Issues Guidance on Self-Dealing Rules for Private Foundations

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IRS Issues Guidance on Self-Dealing Rules for Private Foundations - On March 1, 2022, the IRS published its 128-page Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941. While not...more

McDermott Will & Emery

Weekly IRS Roundup February 8 – February 12, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 8, 2021 – February 12, 2021... On February 9, the Internal Revenue Service announced...more

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...more

Proskauer - Not for Profit/Exempt...

Simplification of the Net Investment Income Tax for Private Foundations

On December 20, 2019, President Trump signed into law changes to the private foundation excise tax on net investment income under Section 4940 of the Internal Revenue Code. For purposes of Section 4940, net investment...more

WilmerHale

The Section 4960 Excise Tax: Application to Tax-Exempt and Affiliated Taxable Entities

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Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more

Katten Muchin Rosenman LLP

Interim IRS Guidance on New Executive Compensation Requirements for Tax-Exempt Entities Creates New Challenges

Under new Section 4960 ("Section 4960") of the Internal Revenue Code of 1986, as amended ("IRC") that was adopted as part of the Tax Cuts and Jobs Act of 2017 (Tax Act), an excise tax under IRC Section 11 (currently 21...more

Snell & Wilmer

New IRS Guidance Throws a Pass to Certain Universities That Pay Coaches Compensation in Excess of $1,000,000

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In Notice 2019-09 (“Notice”), the IRS provides relief from the new excise tax to certain colleges and universities that pay their “covered employees” more than $1 million per year or pay excess parachute payments....more

Carlton Fields

IRS Issues Interim Guidance On Certain 2017 Tax Act Changes Affecting Exempt Organizations: Excess Remuneration and Parachute...

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The IRS issued Notice 2019-09, which provides interim guidance in a fairly lengthy Q&A format relating to Code Section 4960, enacted on December 22, 2017....more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

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Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more

Holland & Knight LLP

Tax Reform's Impact on 401(k) Plan Loan Offset Treatment - Actions for Plan Administrators and Human Resources Benefits Managers

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• The recent Tax Cuts and Jobs Act of 2017 (the Act), enacted on Dec. 22, 2017, contains a few rules that will impact benefit administrators. • This client alert focuses on changes made to the tax treatment of plan loan...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Sheppard Mullin Richter & Hampton LLP

Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock...

Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax...more

Akin Gump Strauss Hauer & Feld LLP

Tax Cuts and Jobs Act

On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its tax reform bill titled the Tax Cuts and Jobs Act (the “House Bill”). On November 6, 2017, Kevin Brady, Chairman of the...more

Katten Muchin Rosenman LLP

House Bill Proposes Major Modifications To Employee Compensation And Benefits-Related Laws; Initial Amendments Provide Limited...

The Tax Cuts and Jobs Act proposed by the US House of Representatives on November 2 (House Bill) proposes major modifications to employee and partner compensation and benefits-related provisions of the Internal Revenue Code,...more

Jones Day

House of Representatives Releases First Draft of Tax Reform Bill

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The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

Dechert LLP

Final US Treasury Regulations Provide Additional Flexibility in Determining the Tax Implications of Money Market Fund Share...

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Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the “Code’), providing for the use of the net asset value (“NAV”) accounting method for transactions in money market fund...more

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