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Section 199A introduced a 20% deduction for qualified business income (previously discussed here). To qualify for the deduction, income must be from a trade or business.

Treasury Department and the IRS established a transfer tax safe harbor for individual donors who fund these accounts, treating qualifying contributions as completed gifts that are not gifts of future interests...

After the Supreme Court declined to review the Ninth Circuit's decision in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Cir. 2019) (cert denied — S. Ct. — (June 22, 2020))...

Earlier this month, two new tax benefits became available to employers hiring workers who were previously unemployed or only working part time. These provisions are part of the Hiring Incentives to Restore Employment Act (the "HIRE Act") enacted into law on March 18.

The IRS released on Jan. 2 its annual guidance related to obtaining private letter rulings, technical advice and the list of issues on which the IRS would not issue a ruling.

Form 8955-SSA is used by plan sponsors to notify the Social Security Administration, via a filing made with the IRS, of participants who have separated from service.

After successfully collecting over $5 billion from offshore voluntary disclosure programs (OVDP) in 2009 and 2011, the IRS extended its OVDP indefinitely.

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services.

On May 22, 2024, the IRS issued Notice 2024-44 (reproduced here), which once again extends the phase-in for Section 871(m) withholding.

The IRS Large Business and International (LB&I) Division set a May 1 effective date for certain changes in the examination process for large taxpayers.

The IRS also ruled that the notes were treated as securities for purposes of Section 361.

The Tax Increase Prevention Act extended 50% bonus depreciation for property placed in service in 2014 and extends the ability to claim unused alternative minimum tax credits in lieu of bonus depreciation.

In January 2019, the Internal Revenue Service (IRS) issued Notice 2019-09, which provides interim guidance for Section 4960 of the Internal Revenue Code of 1986.

We previously advised about significant uncertainties that exist with respect to Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts and related instructions (the “FBAR”) (most notably, with regard to whether US persons who hold interests in offshore hedge funds or offshore private equity funds are required to file FBARs with respect to such interests).

The Internal Revenue Service ("IRS") published details regarding the second Employee Retention Credit Voluntary Disclosure Program (the "Disclosure Program") on August 15, 2024. The Disclosure

Small employers in Wisconsin and Washington that lack a health insurance exchange in their county received some relief from the IRS in the form of a notice

The Internal Revenue Service and the Treasury Department have released guidance implementing the expanded "bonus depreciation" provisions enacted last July as part of the GOP's sweeping tax-and-spending legislation.