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Ballard Spahr LLP

IRS Guidance Expands List of Preventive Care Benefits Under HDHPs

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The IRS recently issued Notices 2024-71 and 2024-75, which expand the list of “preventive care” benefits permitted to be provided by a high deductible health plan (HDHP) without a deductible and the list of benefits...more

Eversheds Sutherland (US) LLP

New IRS guidance expands list of preventive care benefits under a high deductible health plan

On October 17, 2024, the IRS published Notice 2024-75 (Notice), expanding preventive care benefits that can be provided under a high deductible health plan (HDHP) before an individual reaches the applicable minimum HDHP...more

Miller Canfield

IRS Issues FAQs Regarding Long-Term Part-Time Employees in 403(b) Plans

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The IRS recently issued Notice 2024-73, which provides much-needed guidance on long-term, part-time (“LTPT”) employees in ERISA-governed 403(b) retirement plans. Following passage of the SECURE 2.0 Act, an employee is...more

Jones Day

Taxing Tangle: U.S. IRS Releases Guidance for Clean Hydrogen Production Tax Credit

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The U.S. Internal Revenue Service ("IRS") has released proposed regulations regarding the Clean Hydrogen Production Tax Credit introduced in the Inflation Reduction Act of 2022 ("IRA"). The proposed regulations provide more...more

Seyfarth Shaw LLP

Major SECURE 2.0 Guidance Issued: Extra Credit for Repaying Qualified Student Loans

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Seyfarth Synopsis: On August 19, 2024, the IRS issued Notice 2024-63 (the “Notice”) providing guidance for plan sponsors that wish to provide matching contributions based on eligible student loan repayments made by...more

Bricker Graydon LLP

Final Warning: Distributions to Beneficiaries Must Begin in 2025

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The retirement plan industry has been wrestling with the changes to required minimum distribution (RMD) provisions made by the SECURE Act and SECURE 2.0. One issue in particular has caused considerable confusion....more

Baker Donelson

IRS Issues New Guidance on ERC Program – Should You Hold or Fold?

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Over the past week, the IRS has announced two significant developments in its administration and enforcement of the Employee Retention Credit (ERC). Last week, the IRS' three-part announcement signaled: (i) an end to the...more

White & Case LLP

What’s New - Inflation Reduction Act Final PWA Regulations Published

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On June 18, 2024, the Internal Revenue Service (IRS) published its Final Regulations on the Inflation Reduction Act Prevailing Wage requirements ("Final Regulations"). While the Final Regulations generally adhere to the prior...more

Holland & Knight LLP

IRS Proposes to Classify Basket Contracts as a Tax Avoidance Scheme

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The U.S. Department of the Treasury and IRS on July 11, 2024, issued proposed regulations that would classify certain basket contract transactions as listed transactions. Taxpayers and material advisers participating in...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Miller Canfield

IRS Issues Guidance on New Exceptions to 10% Additional Tax on Early Distributions from Retirement Plans

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The Internal Revenue Code generally discourages retirement plan participants from requesting distributions from their retirement plan funds prior to age 59 ½ by imposing an additional 10% tax on those distributions. However,...more

Foley & Lardner LLP

IRS Issues Guidance on Reporting for Digital Assets Transactions

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On Friday, June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final regulations and related guidance on broker reporting related to the disposition of digital assets. This reporting will...more

Holland & Knight LLP

IRS Cracking Down on "Basis-Shifting" in Related-Party Partnership Transactions

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The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

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On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more

Littler

IRS Issues FAQs on Educational Assistance Programs

Littler on

The IRS has issued a new fact sheet (FS-2024-22) to address frequently asked questions about educational assistance programs (EAPs), also known as Section 127 plans....more

Allen Barron, Inc.

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

Allen Barron, Inc. on

What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more

Holland & Knight LLP

IRS Updates Energy Community Bonus Tax Credit Guidance

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The IRS released additional guidance on June 7, 2024, in the form of Notice 2024-48 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

Troutman Pepper

Treasury and IRS Release Updated Guidance on Energy Communities

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On June 7, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2024-48. This notice includes lists of information that taxpayers may use to determine whether they meet certain requirements...more

Holland & Knight LLP

Treasury Department, IRS Issue Section 45Z Clean Fuel PTC Registration Guidance

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The U.S. Department of the Treasury and IRS released Notice 2024-49 on May 31, 2024, regarding the registration requirement and certain other limited guidance under Section 45Z of the Internal Revenue Code. Section 45Z...more

Latham & Watkins LLP

IRS Safe Harbor Eases Path for Domestic Content Bonus Tax Credits

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IRS Notice 2024-41 provides taxpayers with a clearer path toward qualifying for domestic content bonus tax credits through a new elective safe harbor....more

Holland & Knight LLP

Breaking Down the New Domestic Content Safe Harbor Guidance

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The IRS issued Notice 2024-41 on May 16, 2024, which provides updated guidance regarding the domestic content bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The new notice modifies previously...more

DarrowEverett LLP

New Domestic Content Adder Guidance: ‘Buy American’ is Back

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On May 16, 2024, the Department of the Treasury and the IRS announced the release of Notice 2024-41, which clarifies the safe harbor for classification of project components created in Notice 2023-38 and provides a new safe...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Holland & Knight LLP

Guidance, Model Provide Additional Clarity for 40B Sustainable Aviation Fuel Tax Credit

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The U.S. Department of the Treasury and IRS released Notice 2024-37 on April 30, 2024, regarding the Sustainable Aviation Fuel (SAF) Tax Credit found at Section 40B of the Internal Revenue Code as an income tax credit and...more

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