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IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Better Late Than Never - The IRS Issues Final Regulations on the Allocation of Recourse Partnership Liabilities After More Than a...

On November 29, 2024, the United States Internal Revenue Service (the “IRS”) released final regulations (Final Regulations) relating to the allocation of recourse partnership liabilities under section 752 of the Internal...more

[Event] 2025 Winter Tax Forum - February 6th, Richmond, VA

Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more

[Webinar] Winter Tax Forum - January 19th, 9:00 am - 10:00 am ET

We hope you can join us for our Winter Tax Forum on Thursday, January 19, 2023. Employee benefits and executive compensation partner Nona Massengill will provide an overview of the tax issues that impact equity...more

IRS Denies Deduction for Forgiven PPP Loan Amounts Used for Business Expenses

In Notice 2020-32, released April 30, the IRS determined that expenses paid using the proceeds of Paycheck Protection Program (PPP) loans (Covered Loans) are not deductible expenses for income tax purposes if those loans...more

IRS Provides Additional Relief for Taxpayers Affected by COVID-19

On April 9, 2020, the Department of the Treasury (Treasury Department) and the Internal Revenue Services (IRS) issued Notice 2020-23, announcing that certain additional tax return filing and payment deadlines have been pushed...more

IRS Provides Guidance on NOL Carryback and Section 163(J) Elections

In a flurry of guidance, the Internal Revenue Service (IRS) has issued Revenue Procedure 2020-22, Revenue Procedure 2020-24, and Notice 2020-26 providing guidance to taxpayers wanting to elect out of new net operating loss...more

IRS Relief for Partnerships Wanting to Amend Tax Returns

On April 8, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-23 (the Revenue Procedure) allowing eligible partnerships subject to the centralized partnership audit regime (CPAR) to amend 2018 and 2019...more

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