News & Analysis as of

Internal Revenue Code (IRC) Third-Party

Holland & Hart LLP

Fund Formation and Credit Transfers: Monetizing Tax Credits Using Partnerships

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Section 6418 of the Internal Revenue Code (as added by the Inflation Reduction Act of 2022) allows an eligible taxpayer that qualifies for certain clean energy tax credits, including investment tax credits and production tax...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

Rivkin Radler LLP on

The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Pullman & Comley - Labor, Employment and...

Mortgage or other Third Party Loan Investments in Your Plan?  Do they Pass Muster under IRS Issue Snapshot?

The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more

Mintz - Employment Viewpoints

Health Plan Transparency and the Case for Welfare Plan Fiduciary Committees

The Consolidated Appropriations Act, 2021 (the “Act”) adopted a series of transparency requirements that apply to employer-sponsored group health plans. These transparency rules impose a series of new and complex obligations...more

Freeman Law

No Right to Intervene?—IRS Third-Party Summonses

Freeman Law on

Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more

McDermott Will & Emery

IRS Acknowledges Limitations on Use of Outside Contractors in Audits

McDermott Will & Emery on

Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more

Foodman CPAs & Advisors

Does your Third-Party FATCA Consultant have the experience to interpret the complex US Tax Code?

Foreign Financial Institutions (FFIs) have multiple FATCA reporting compliance responsibilities and face the possibility of penalties for not complying. ...more

Foodman CPAs & Advisors

Taxpayers can be Embarrassed when IRS Contacts a Third-Party

Under Internal Revenue Code (IRC), Subtitle F - Income Taxes, Chapter 78 - Discovery of Liability and Enforcement of Title, Subchapter A - Examination and Inspection – Section 7602, the IRS has the authority to contact a...more

McDermott Will & Emery

Ninth Circuit Interprets Summons Notice Rules Strictly Against IRS

The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek...more

Foodman CPAs & Advisors

Can the IRS release Taxpayer information to a third party?

Tax Return information is protected from disclosure by the IRS to other parties by the IRC Section 6103 -Confidentiality and Disclosure of Returns and Return information. ...more

Gerald Nowotny - Law Office of Gerald R....

The Walking Dead - Using Private Placement Variable Deferred Annuity Contracts to Enhance the Investment Return in Life Settlement...

Overview - I have always been a film fan. Growing up in the Panama Canal Zone, one of my Mother’s jobs for the Panama Canal Company was serving as the manager of the Balboa Theater. We used to watch initial screenings of...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Advisors Advantage - August 2014

Dealing with adversity. It's about how you deal with it. I'm a huge Aerosmith fan since high school and it's because the music resonates with me because it reminds me of the experiences that I have gone through...more

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