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The IRS has issued a private letter ruling addressing whether an option to acquire a partnership interest should be taken into account for purposes of determining whether the buyer acquired the target partnership’s corporate subsidiaries in a "covered transaction."

The IRS, in conjunction with states and stakeholders in the tax preparation and software industry, intends to take additional steps to protect taxpayers from tax-related identity theft, the agency announced at the 2016 Security Summit.

On May 5, 2015 the IRS announced in a news release that victims of the severe storms that occurred beginning April 2, 2015 in certain parts of Kentucky may be able to delay filing certain tax returns until July 31, 2015.

In a memorandum released on August 18, 2023 (CCM 202333001), the IRS Office of Chief Counsel clarified the eligibility of federal credit unions...

The IRS has concluded in field attorney advice that two corporations formed immediately prior to an asset sale were ignored for U.S. federal income tax purposes.

The IRS announced late Wednesday, March 17, 2021 that it is moving the federal income tax filing deadline for individuals to May 17, rather than April 15.

The IRS determined what a taxpayer must do if it has deferred recognizing revenue into income under Rev. Proc. 2004-34 and its stock is subsequently acquired by an unrelated corporation...

The IRS has issued additional transition relief (Notice 2016-40) for employers who claim the work opportunity tax credit (WOTC) for employees hired between Jan. 1, 2015, and Aug. 31, 2016.

Recently, the Internal Revenue Service ("IRS") announced an initiative to monitor tax-exempt health care organizations to ensure compliance with section 4958 of the Internal Revenue Code of 1986, as amended, regarding excess benefit transactions. Specifically, the IRS is looking at compensatory arrangements between a tax-exempt health care organization and a disqualified person to determine if an excess benefit transaction has occurred. A disqualified person includes any person in a position to

The IRS has released a private letter ruling extending the time for a corporation to elect safe harbor treatment under Rev. Proc. 2011-29 for a success-based transaction fee.

On November 23, 2020, the IRS and Treasury issued final regulations (T.D. 9935) that amend and finalize proposed regulations issued in June, 2020.

Treasury and the IRS intend to issue regulations addressing the application of Section 901(m) to disposition of assets following covered asset acquisitions.

The sponsors of those plans are permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions are satisfied.

The IRS has issued guidance that responds to Historic Boardwalk Hall, LLC v. Commissioner, in which the Third Circuit held that an investor in a partnership who did not have any meaningful downside risk or upside potential was not a bona fide partner for federal tax purposes, and was therefore not entitled to an allocation of 99.9% of the historic rehabilitation tax credits under Section 47.

The Internal Revenue Service recently issued Revenue Procedure 2026-6, which provides procedural guidance allowing States to make an Advance Election to participate...

The U.S. Department of the Treasury and IRS have issued temporary regulations establishing the framework for a new Federal Scholarship Tax Credit program that will allow eligible individuals to receive tax credits for contributions to scholarship granting organizations. These regulations outline the participation requirements for states and organizations, including registration procedures, contribution standards, and compliance measures that will govern the program beginning in 2027.

In September, the IRS issued Rev. Proc. 2018-52 updating the IRS correction program, i.e., Employee Plans Compliance Resolution System ("EPCRS").