News & Analysis as of

U.S. Treasury Disclosure Requirements Internal Revenue Service

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Proskauer - Tax Talks

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

Proskauer - Tax Talks on

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

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Fox Rothschild LLP

Law Firms Guiding Compliance With Corporate Transparency Act as FinCEN Sets Deadlines

Fox Rothschild LLP on

The Corporate Transparency Act is now poised to take effect on January 1, 2024 (the “Effective Date”), and will immediately impose sweeping new disclosure duties when new entities are formed. During 2024, the other CTA shoe...more

DirectEmployers Association

OFCCP Week In Review - January 2023

Wednesday, November 30, 2022: U.S. IRS & Treasury Department Published Notice on Prevailing Wage & Apprenticeship Requirements for Enhanced Tax Benefits Under Inflation Reduction Act - U.S. DOL Wage & Hour Division Seeking...more

McDermott Will & Emery

Weekly IRS Roundup November 7 – November 11, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 7, 2022 – November 11, 2022....more

McDermott Will & Emery

IRS Hints at Revenue Procedure 94-69 Update

McDermott Will & Emery on

At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Proskauer - Not for Profit/Exempt...

IRS Issues Final Regulations on Nonprofit Donor Disclosure Requirements

On May 26, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) relaxing nonprofit donor disclosure requirements under section 6033 of the Internal...more

Akin Gump Strauss Hauer & Feld LLP

Developments in Cryptocurrency in 2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Tucker Arensberg, P.C.

Urgent Captive Insurance Alert: IRS Lists 831(b) Micro-Captives as “Transaction of Interest”

Tucker Arensberg, P.C. on

On November 1, 2016, via Notice 2016-66 (2017-47 IRB) (link to notice), the Treasury Department and IRS declared certain captive insurance transactions under Code section 831(b) as “transactions of interest.” Commonly...more

A&O Shearman

Focus on Tax Controversy and Litigation - Treasury and IRS Issue Proposed Regulations Imposing Documentation Requirements Under...

A&O Shearman on

In addition to the discussion of the recently proposed regulations which impose new documentation requirements under Section 385, this month’s issue features articles regarding the Circuit Court decision in Chemtech Royalty...more

BCLP

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

BCLP on

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

Blank Rome LLP

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

Blank Rome LLP on

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

Proskauer - Employee Benefits & Executive...

Agencies Issue Final Regulations on the Summary of Benefits and Coverage (SBC) Requirements

As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more

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