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The IRS recently issued notices 2012-58 and 2012-59 to provide guidance on certain new rules under the Patient Protection and Affordable Care Act (PPACA).

The IRS has issued a notice previewing future guidance and seeking comments from the public on the Section 4980I excise tax for employer-sponsored health plans that exceed certain cost thresholds.

The IRS has issued proposed regulations (REG-141268-11) under Treas. Reg. Sec. 1.312-11 related to the allocation of a corporation’s earnings and profits (E&P) upon a transfer under section 381(a).

The IRS has issued temporary regulations (T.D. 9598) under Section 988 related to integrated transactions that involve foreign currency denominated debt under Treas. Reg. Sec 1.988-5.

The IRS has issued proposed regulations (REG-138759-14) to refine the application of Section 732(f) in certain factual situations related to the distribution of stock to corporate partners.

The IRS has issued proposed regulations (REG-139991-08) that deal with various rules for transfers of property to RICs and REITs.

The IRS on Dec. 16 issued Notice 2014-1 to provide guidance on the application of the cafeteria plan rules under Section 125 under Section 223, and how those rules relate to participation by same-sex spouses following the Supreme Court’s decision in United States v. Windsor, 570 U.S.

The IRS has released a statement confirming that calendar-year C corporations that timely file an extension will be granted an automatic six-month extension to file an income tax return.

In fall 2013 the IRS issued Notice 2013-54 to provide guidance on how the market reforms of the Affordable Care Act (ACA) apply to health reimbursement arrangements (HRAs).

In Private Letter Ruling (PLR) 201214020, the IRS ruled that under Section 1504(a)(3), a spun-off corporation (Controlled) was not a "successor" to a distributing corporation (Distributing).

In a private letter ruling (PLR 201341015), the IRS ruled that parking revenue received by a real estate investment trust (REIT) from certain parking facilities under parking management agreements with various taxable REIT subsidiaries qualified as rents from real property for purposes of Section 856(d).

The IRS issued guidance that allows taxpayers to use a simplified proportional method of accounting to compute original issue discount for pools of credit card receivables.

Congressional tax writers spent much of last week debating anti-inversion tax proposals.

The Ninth Circuit ruled in Flextronics America et al. v. Commissioner (No. 11-70949) that the acquisition of assets and their transfer immediately afterward did not constitute a sham transaction that should be disregarded for U.S. federal income tax purposes.

The IRS concluded in an internal legal memorandum released Feb. 13 that a taxpayer’s nonrecourse liability affected its mark-to-market computation under Section 475(a).

The Organisation for Economic Co-operation and Development (OECD) on Oct. 5 released its highly anticipated final package on base erosion and profit shifting (BEPS) measures.

The IRS determined that payments received by automobile dealerships from automobile manufacturers under a facility image-upgrade program were income.