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The IRS has issued final regulations for determining whether disregarded entities can be considered the "taxpayer" for the bankruptcy and insolvency exceptions to cancellation of debt income rules.

The IRS has issued guidance providing a safe-harbor for determining whether certain debt constitutes qualified real property business indebtedness under Section 108(c)(3).

The IRS provided guidance on how certain provisions of the Patient Protection and Affordable Care Act apply to health reimbursement arrangements, health flexible spending arrangements and certain other employer health care arrangements.

The IRS has issued proposed regulations under Section 453B relating to the nonrecognition of gain or loss on certain dispositions of an installment obligation.

The IRS has issued temporary and proposed regulations (T.D. 9592 and REG-107889-12) adopting a bright line test for determining whether a foreign corporation satisfies the substantial business activities test of Section 7874(a)(2)(B)(iii) to avoid treatment as an inverted corporation.

The IRS issued temporary regulations under Treas. Reg. Sec. 1.337(d)-3T (T.D. 9722) that are intended to prevent corporate taxpayers from using a partnership to circumvent gain...

A recently released IRS program manager technical assistance (PMTA) memorandum (PMTA 2014-018) is a reminder of the importance of timely and complete filing of international information returns.

The IRS has proposed regulations under Section 4980H on a large employer’s responsibility to provide health insurance coverage to employees.

The IRS has released interim guidance providing an alternative method for payment processors to determine if they must report payments to offshore accounts under Section 6050W.

The IRS recently issued corresponding guidance providing for penalty relief for some late filers of information returns for certain retirement plans.

The IRS has provided various forms of relief aimed at assisting Louisiana flood victims and their families.

The IRS recently released final regulations (T.D. 9716) that clarify two issues under Section 162(m), which limits a public corporation's compensation deduction to $1 million per year for each covered employee.

The IRS reopened on Oct. 17 as Congress came to an agreement late Oct. 16 to fund the government and raise the debt ceiling.

In a private letter ruling (PLR 201341004), the IRS ruled that a valid spinoff had occurred notwithstanding that some of the distribution was related to hook stock in the parent.

The IRS ruled in a private letter ruling that a consent fee a debtor paid its creditors was a modification of the underlying debt.

Under Sections 871 and 881, interest must be paid on an obligation that is in registered form to qualify as portfolio interest.

There are many reasons that international tax changes are a poor fit to pay for highway funding and are unlikely be enacted outside of the context of broader business reform.