The IRS Large Business and International Division has instructed its examiners that under some circumstances, they should not challenge a taxpayer’s treatment of milestone payments made to investment bankers.

The IRS recently released final forms that employers must use to report health coverage that they offer to their employees.

The IRS has ruled in PLR 2012-14-007 that no portion of amounts paid by an electric company to acquire wind energy facilities subject to facility-specific power purchase agreements will be allocated to the agreements and that the purchase price of the facilities that can be attributed to the agreements will be used in determining the adjusted basis of the facilities.

The IRS on July 13 issued guidance (Notice 2012-39) to prevent earnings repatriations in certain Section 367(d) cross-border reorganizations.

Section 41 generally allows a taxpayer to claim a 20% "regular credit" for costs exceeding a base amount.

Policymakers in federal and state governments continue to focus on targeted hiring-related tax credits.

The automatic spending cuts required by the budget "sequestration" took effect on March 1 without legislative action, but tax reform efforts gained ground last week.

The 21st Century Cures Act, enacted on Dec. 13, 2016, added Section 9831(d) to the code to allow eligible small employers to offer QSEHRAs to employees without violating the market reforms established by the Affordable Care Act (ACA).

The Court of Federal Claims has ruled in Dynetics Inc. v. United States (No. 12-576T) that Dynetics didn't qualify for an R&D credit because its research was funded by another party.

In PLR 201438006, the IRS ruled that a Section 83(b) election was valid even though the taxpayer failed to attach a copy of the election to his Form 1040.

The directive itself does not change any of the ACA coverage or tax requirements.

During the past twenty years, many provinces have simplified their legislation governing limitation periods. One remaining complexity is that courts have continued to assess...

Tax Court has held in Castigliola v. Commissioner that three lawyers who were member-managers of a PLLC classified as a partnership for U.S. federal income tax purposes were not entitled to exclude a portion of their partnership income...

The IRS concluded that a taxpayer, a professional moving company, couldn’t use the recurring item exception to economic performance for its payments to customers.

On November 14, 2012, the U.S. Securities and Exchange Commission (SEC) issued an Order providing further regulatory relief and assistance to a broad class of companies and others affected by Hurricane Sandy.

In Notice 2015-28, the IRS extended the temporary nondiscrimination relief originally provided in Notice 2014-5 for certain "closed" defined benefit pension plans.

The proposed regulations would apply to taxable years beginning on or after the final regulations' publication date. Taxpayers may rely on the proposed regulations until they become final.

Newly proposed changes to benefit plan reporting on Form 5500 would have a significant impact not only on employers but also on participants, fiduciaries and third-party service providers.

The IRS on Nov. 6 issued final regulations under Treas. Reg. Section 1.1001-4 (T.D. 9639), which provide that certain transfers or assignments of a derivative do not result in exchange treatment for the nonassigning counterparty.

As you learn more about the details of the fiscal cliff legislation, keep these three key points in mind: