A Treasury regulation provides that a researcher performing technological research for its customer is not entitled to federal income tax credits for the cost of the research if the researcher does not retain substantial...more
Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable.
The...more
Key Takeaways -
..The pending case, Silver v. Internal Revenue Service, will provide insight, when decided, of the view of the Court of Appeals for the District of Columbia Circuit on the scope of judicial review of...more
6/27/2022
/ Administrative Appeals ,
Appeals ,
Article III ,
Income Taxes ,
Judicial Review ,
NPRM ,
Regulatory Flexibility Act ,
Reporting Requirements ,
Small Business ,
Standing ,
U.S. Treasury
On Friday, Aug. 28, 2020, the Department of the Treasury released Notice 2020-65 (the "Notice") which provides some long-awaited guidance for the payroll tax deferral announced in the Presidential Memorandum issued by...more
On Saturday, Aug. 8, Pres. Donald Trump signed the "Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster," providing that the withholding, deposit, and payment of the employee's portion of...more
Recognizing the challenges facing employee benefit plan sponsors, administrators, and participants, on April 28, 2020, the Departments of Treasury (“DOT”), Labor (“DOL”) and Health and Human Services (“HHS”) extended certain...more
5/1/2020
/ Benefit Plan Sponsors ,
COBRA ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Authority ,
Final Rules ,
State of Emergency ,
Time Extensions ,
U.S. Treasury
Employer-sponsors of certain retirement plans have work to do prior to the end of 2019. Sponsors of Internal Revenue Code ("Code") section 401(k) and 403(b) plans must analyze their plan documents and associated...more
8/25/2019
/ 401k ,
403(b) Plans ,
Benefit Plan Sponsors ,
Employee Benefits ,
Hardship Distributions ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Popular ,
Proposed Regulation ,
Retirement Plan ,
Safe Harbors ,
U.S. Treasury