News & Analysis as of

Reporting Requirements Internal Revenue Code (IRC) U.S. Treasury

Freeman Law

Propuesta de Reglamentación para Fideicomisos Extranjeros Análisis de la Sección 643(i) del IRC

Freeman Law on

El 8 de mayo de 2024, la Secretaría de Hacienda de los Estados Unidos (“Treasury Department”) dio a conocer propuestas de reglamentos que abordan la clasificación, tributación y requisitos de información para fideicomisos...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Holland & Hart - Employers' Lawyers

IRS Issues Final Prevailing Wage and Apprenticeship Regulations

On June 25, 2024, the Internal Revenue Service and U.S. Department of Treasury published final Treasury Regulations (“Final Regulations”) in the Federal Register on the prevailing wage and registered apprenticeship...more

Freeman Law

Proposed Regulations on Loans of Cash and Property from Foreign Trusts

Freeman Law on

On May 8, 2024, the Treasury Department issued proposed regulations regarding the classification, taxation, and reporting of foreign trusts. The proposed regulations were issued for sections 643(i), 679, 6039F, 6048, and 6677...more

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

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The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...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

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Sherman & Howard L.L.C.

FinCEN Implies Certain Tax-Exempt Entities Are Subject to the CTA (They’re Not)

As companies across the nation grapple with the reality of complying with the Corporate Transparency Act (CTA), which went into effect on January 1 of this year, certain nonprofits that expected to be exempt from such toils...more

Levenfeld Pearlstein, LLC

Corporate Transparency Act Reporting Requirements: What Do Illinois Community Associations Need to Know?

In 2021, Congress enacted the Corporate Transparency Act (“CTA”) in an effort to protect the U.S. financial system from illicit use. Generally speaking, the CTA requires business entities operating in the U.S. to report...more

Cooley LLP

Transitional Tax Reporting Guidance for Business Transactions Involving Digital Assets

Cooley LLP on

In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Verrill

Safe Harbor Exception for De Minimis Dollar Amount Reporting Errors

Verrill on

As part of the routine administration of employee benefit plans, shortly after the end of a calendar year, many transactions must be reported to the federal government (“information returns”) and participants (“payee...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

McDermott Will & Emery on

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

Paul Hastings LLP

IRS Issues Proposed Regulations for Digital Asset Reporting

Paul Hastings LLP on

The Internal Revenue Service and Treasury Department have issued long-awaited Proposed Regulations for parties that will be required to report transactions involving digital assets. These newly identified parties will need to...more

BakerHostetler

Digital Asset Broker Regulations Target DeFi Platforms and Payment Processors

BakerHostetler on

The Internal Revenue Service (IRS) and the Department of the Treasury issued a 282 page notice of proposed rulemaking regarding digital assets and broker reporting on Aug. 26 (the Proposed Regulations), nearly two years after...more

Sullivan & Worcester

Treasury and IRS Issue Proposed Regulations for Tax Reporting Requirements on Digital Asset Transactions

Sullivan & Worcester on

On August 29, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS”) published proposed regulations that, if finalized, would require brokers (including digital asset trading platforms, digital asset...more

Fenwick & West LLP

IRS Delays Infrastructure Act's Broker Reporting Requirements

Fenwick & West LLP on

On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more

Morgan Lewis

Digital Asset Brokers: Proceed with Caution

Morgan Lewis on

The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A. The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more

McDermott Will & Emery

Welcome (But Last Minute) Relief for Prescription Drug Reporting Originally Due December 27

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Section 204 of Title II of Division BB of the Consolidated Appropriations Act, 2021 amended the Internal Revenue Code, the Employee Retirement Income Security Act of 1974 and the Public Health Service Act to add rules...more

Morrison & Foerster LLP

New Cryptocurrency Reporting Requirements

Morrison & Foerster LLP on

Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more

Fenwick & West LLP

Senate Passes Infrastructure Bill Including Language on Digital Assets and Reporting of Crypto Transactions

Fenwick & West LLP on

On August 10, 2021, the U.S. Senate passed an infrastructure bill containing explicit rules to be inserted into the Internal Revenue Code regarding digital assets. The passage marks the first time that language on this topic...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...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

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