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Article
IRS Releases Final Regulations For Reporting Of Specified Foreign Financial Assets
On Dec. 12, the IRS released final regulations under Section 6038D https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-29125.pdf (T.D. 9706) relating to the provisions of the Hiring Incentives to Restore Employment (HIRE) Act that require specified foreign financial assets to be reported to the IRS for taxable years beginning after March 18, 2010.
United StatesTax
Grant Thornton LLP
Article
IRS Reverses Itself On Treatment Of 'Bad Boy Guarantees'
In February 2016, the IRS released an internal memorandum concluding that typical 'bad boy guaranties' provided by a partner for partnership debt should be treated as a recourse liability of the guarantor...
United StatesTax

Herbert Smith Freehills Kramer LLP

IRS Rules On Insurance For Employer-Provided Retiree Health Benefits

The IRS held that a certain arrangement in which employers fund their retiree health benefits through a wholly owned subsidiary was insurance.

United StatesTax

Grant Thornton LLP

IRS Rules On Section 382 Bankruptcy Reorganization Of A Consolidated Group

The IRS addressed a reorganization in which some members of a consolidated group were under Chapter 11 bankruptcy protection and some members were not.

United StatesTax

Grant Thornton LLP

IRS Suspends For Further Study Contributions To 501(C)(4) Organizations

In a directive issued today to IRS offices, the Service is suspending any further examination activity on the gift tax treatment of contributions to 501(c)(4) organizations.

United StatesTax

McGuireWoods LLP

IRS To Limit Some Corporate Private Letter Ruling Requests

The IRS announced in Rev. Proc. 2013-32 that it would restrict the scope of private letter rulings for Section 355 distributions, Section 332 liquidations, Section 351 exchanges, Section 368 reorganizations and Section 1036 recapitalizations.

United StatesTax

Grant Thornton LLP

IRS To Resume Issuing Certain Guidance

It is unclear what impact this executive order has on the promulgation of new Treasury regulations, which tend to interpret statutes.

United StatesTax

Grant Thornton LLP

IRS Transitioning To Electronic Payments For Rulings And Requests

The IRS announced that beginning on Aug. 15, taxpayers who request certain rulings from the IRS, such as private letter rulings (PLRs), closing agreements, and accounting method changes...

United StatesTax

Grant Thornton LLP

IRS Updates Guidance On Application Of Windsor To Qualified Retirement Plans

The IRS updated guidance previously provided in Notice 2014-19 concerning when qualified retirement plans must recognize same-sex marriages.

United StatesTax

Grant Thornton LLP

IRS Updates Notice Determining When Construction Begins For Purposes Of The Production Tax Credit And Investment Tax Credit

Last week, we reported that the Internal Revenue Service issued Notice 2013-29 to provide guidance on eligibility for the production tax credit and investment tax credit.

United StatesTax

McDermott Will & Emery

Israel Tax Authority Extends Deadline For Registration Of U.S. Trusts With Israeli Beneficiaries

The Israel Tax Authority announced yesterday that the deadline for registration of Family Trusts (sometimes referred to as Relatives Trusts), which are trusts created by a living U.S. grantor for the benefit of at least one Israeli resident beneficiary, has been extended from June 30, 2015 to December 31, 2015.

United StatesTax

Fox Rothschild LLP

July 2016 Tax Compliance Calendar

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.

United StatesTax

Brown Smith Wallace

LB&I Imposes Tighter Timeline For Information Document Requests

The IRS Large Business and International Division has announced new, mandatory issuance and enforcement procedures for information document requests.

United StatesTax

Grant Thornton LLP

Legislative Proposals And Year End Tax Planning (Podcast)

It's mid-November and the new tax proposals are still up in the air. What should practitioners and tax payers do to protect assets, plan estates and minimize taxes in this unknown environment.

United StatesTax

"Littlejohn Notices" Continue To Cause Big Headaches For Taxpayers

Earlier this year, the IRS confirmed that over 400,000 taxpayers were victims of IRS contractor Charles Littlejohn's 2019 leak of taxpayer data...

United StatesTax

Hogan Lovells Cadwalader

LLC ESOP

In what appears to be the first ruling of this nature, the Internal Revenue Service recently issued a private letter ruling to the effect that a limited liability company may adopt an employee stock ownership plan.

United StatesTax

Stoll Keenon Ogden PLLC

Louisiana Expands Marketplace Facilitator Definition To Include Accommodations Intermediaries

On June 4, 2025, Governor Jeff Landry signed Act 82 into law, making changes to the definition of "marketplace facilitator" for nexus purposes.

United StatesTax

Maintaining Privilege With Non-Lawyer Experts Under Kovel

Holland & Knight Partners Abbey Garber and Denise Mudigere, along with Associate Kate Minnich, co-authored an article in the December 2021 issue of Headnotes, a publication of the Dallas Bar Association.

United StatesTax

Holland & Knight

Manufacturing Communities Investment Act Would Extend And Increase NMTC Program

In response to the decline in manufacturing jobs in certain parts of the Country, the Manufacturing Communities Investment Act was introduced to the Senate.

United StatesTax

Duane Morris LLP

May 2016 Tax Compliance Calendar

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.

United StatesTax

Brown Smith Wallace

Showing 401–420 of 9341 results

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