News & Analysis as of

Internal Revenue Code (IRC) Income Taxes

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Cole Schotz

RetireReady NJ: Reminder About The Requirements Under The New Jersey Secure Choice Savings Program Act

Cole Schotz on

Employers with at least 25 employees in New Jersey that do not already offer a qualified retirement plan to employees must take action to facilitate the RetireReady NJ Retirement Savings Program (“RetireReady NJ”)....more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Wilson Sonsini Goodrich & Rosati

Eligibility of Life Sciences Companies for Qualified Small Business Stock

The “qualified small business stock” (QSBS) tax exemption under Section 1202 of the Internal Revenue Code allows non-corporate founders and investors in certain emerging growth companies organized as corporations to...more

Foley & Lardner LLP

Tax Court Reaffirms Soroban Holding that “Active” Limited Partners are Subject to Self-Employment Tax

Foley & Lardner LLP on

On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more

Farella Braun + Martel LLP

Nonprofit Basics: Unrelated Business Income Tax: Basic Rules for Charities - Part 1

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and episode 107 is the first in a series of technical episodes describing the basic principles of the tax on unrelated business income generated...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Holland & Knight LLP

Final Regulations Issued on Penalty Supervisory Approval

Holland & Knight LLP on

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

Sheppard Mullin Richter & Hampton LLP

Reminder about Annual ISO/ESPP Reporting in January 2025 and New Section 83(b) Election Form

Annual Reporting on ISO/ESPP Transactions - As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require...more

Blank Rome LLP

New Jersey Tax Court Rules That Individuals Are Not Subject to Tax on “Deemed Dividends” under IRC Section 965

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The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income...more

Fenwick & West LLP

Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles

Fenwick & West LLP on

Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more

Holland & Knight LLP

IRS Notifies Thousands of Taxpayers After Personal Information Disclosed

Holland & Knight LLP on

The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more

McDermott Will & Emery

Five Key Takeaways From the Proposed PTEP Regulations

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Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

DarrowEverett LLP

The Tax Implications of Divorce: Alimony, Child Support, IRAs and More

DarrowEverett LLP on

Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and...more

McDermott Will & Emery

IRS Roundup for November 25 – December 13, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2024 – December 13, 2024....more

ArentFox Schiff

Residency Determination for US Federal Estate and Gift Tax Purposes and Choice of US Federal Estate Tax Blockers

ArentFox Schiff on

The term “resident” is defined differently for US federal income tax purposes and US federal estate and gift tax purposes. The mismatch in the US resident status under the two tax regimes often gives rise to problems. Thus,...more

Alston & Bird

IRS Releases New Section 83(b) Election Form

Alston & Bird on

Our Federal Tax Group explains the new standardized Form 15620 that taxpayers can use when receiving property that is subject to a “substantial risk of forfeiture.”...more

Burr & Forman

Tax-Exempt NIL Collectives Warned of “Smarter Enforcement” by IRS in 2025

Burr & Forman on

The Tax Exempt & Government Entities Division (TE/GE) of the Internal Revenue Service (IRS) recently published a program letter outlining the Division’s priorities in fiscal year 2025. The Division lists “tax-exempt...more

Stinson LLP

1099-K Reporting: More Time to Transition to the $600 Reporting Threshold

Stinson LLP on

In the American Rescue Plan Act of 2021, Congress and the Biden administration lowered the minimum reporting threshold for filing information returns relating to “reportable payment transactions” (a payment card is accepted...more

Foodman CPAs & Advisors

Forms 3520 and 3520-A Late Filing get IRS Relief

On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – November 22, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024. ...more

Gray Reed

Giving Season: Tax Edition

Gray Reed on

With the holiday season officially upon us, the Dollars and Sense team wants to make sure you maximize your giving and gifting! For so many businesses, and business owners, this time of year also means employer festivities,...more

Farrell Fritz, P.C.

International Tax Changes on the Horizon

Farrell Fritz, P.C. on

There are two recent taxpayer-friendly updates of note in the international tax filing arena. First, Internal Revenue Service (“IRS”) Commissioner Danny Werfel recently announced that the IRS is ending its automatic...more

McDermott Will & Emery

Weekly IRS Roundup November 11 – November 15, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11, 2024 – November 15, 2024. November 11, 2024: The IRS released Internal Revenue Bulletin...more

Morgan Lewis - ML Benefits

Increased Scrutiny of Payee Provided Addresses Required By New IRS Regulations to Ensure Proper Withholdings

Internal Revenue Code Section 3405(e)(13) generally requires mandatory withholding on periodic and nonperiodic distributions that are to be delivered outside the United States unless the payee is a nonresident alien or recent...more

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