News & Analysis as of June 7, 2025

Income Taxes › Internal Revenue Service

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

The IRS Continues Winning Self-Employment Contributions Act (SECA) Tax Against Limited Partners in Private Equity and Hedge Funds

White & Case LLP on 6/5/2025

Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on 6/5/2025

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

The Powers and Perils of Intrafamily Loans

Warner Norcross + Judd on 6/4/2025

It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more

Court Decision on Limited Partner Exception to Self-Employment Tax

WilmerHale on 6/3/2025

On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more

Proposed Tax on Certain Outbound Remittances

Seward & Kissel LLP on 6/3/2025

In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on 5/30/2025

Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Terminating a Trust? Don’t Forget to Consider This Tax Issue

Rivkin Radler LLP on 5/29/2025

Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

“No Tax on Tips Act” Passes U.S. Senate With Unanimous Consent

Stokes Wagner on 5/27/2025

On May 20, 2025, the U.S. Senate passed the “No Tax on Tips Act” with unanimous consent. The bill now heads to the U.S. House of Representatives. If passed, the “No Tax on Tips Act” would allow employees in tipped...more

From Beats to Bills: How DJs Tiësto and Afrojack Were Entangled in a $100M Offshore Tax Scheme

Fleurinord Law PLLC on 5/23/2025

Spinning the Globe: When the Music Stops, the IRS Listens - Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto...more

Posts, Profits, & Penalties | Tax Law & Social Media | Part 3

Freeman Law on 5/22/2025

The IRS Has Eyes - Having any presence on social media—even sans influencer following or income—can and may be used against you by the IRS. Have you ever Googled yourself? You will likely be shocked at how much...more

“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit

McDermott Will & Emery on 5/21/2025

A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit...more

IRS Roundup May 2 – May 13, 2025

McDermott Will & Emery on 5/20/2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025. IRS GUIDANCE - May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing...more

House tax bill proposes changes to information reporting rules

Eversheds Sutherland (US) LLP on 5/16/2025

On May 14, 2025, the House Ways and Means Committee approved the “One, Big, Beautiful Bill,” containing the tax provisions destined for the budget reconciliation package. Several of the bill’s provisions would affect...more

Income Tax and State Family Medical Leave Benefits

Bowditch & Dewey on 5/13/2025

Earlier this year, the Internal Revenue Service issued long awaited guidance on the taxation of paid family medical leave. The revenue ruling is effective for payments received on or after January 1, 2025....more

HSA/HDHP Limits for 2026

Stinson - Benefits Notes Blog on 5/7/2025

On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs)....more

IRS Announces HSA and HDHP Limits for 2026

Stoel Rives - Health Law Insider® on 5/5/2025

The Internal Revenue Service has released Rev. Proc. 2025-19 announcing the inflation-adjusted limits for high deductible health plans (HDHPs) and health savings accounts (HSAs) in 2026. The updated 2026 limits are as...more

Documentation is Key When Claiming QSBS Benefits

Keating Muething & Klekamp PLL on 4/30/2025

In recent years, the utilization of qualified small business stock (“QSBS”) under Section 1202 has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax...more

The $5 Million Hush Money Payment in White Lotus Season 3

Mandelbaum Barrett PC on 4/30/2025

The explosive finale of White Lotus Season 3 left fans with more than just plot twists—it raised fascinating legal and tax questions. Chief among them: what are the implications of Greg’s $5 million wire transfer to Belinda,...more

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

Cadwalader, Wickersham & Taft LLP on 4/30/2025

The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

Ballard Spahr LLP on 4/23/2025

It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Section 83(b) Elections — Should You Pay Taxes Now?

Patterson Belknap Webb & Tyler LLP on 4/23/2025

In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

Hobby Loss Rules Revisited

Foster Garvey PC on 4/23/2025

With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Made a Mistake on Your Tax Return? What to Do if You Filed Incorrectly

Bowditch & Dewey on 4/23/2025

Mistakes happen, and the tax law can be complex and ambiguous. The question becomes, what does a taxpayer do if they discover a mistake on their tax return? Should an amended tax return be filed? In some cases, the taxpayer...more

President Names Yet Another Acting IRS Commissioner

Fox Rothschild LLP on 4/22/2025

Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more

Federal Circuit Holds Generic’s Hatch-Waxman Litigation Expenses Deductible

Axinn, Veltrop & Harkrider LLP on 4/17/2025

A March 21 Federal Circuit decision in Actavis Laboratories FL, Inc. v. United States, No. 23-1320 (Fed. Cir. Mar. 21, 2025) marked a victory for generic drug developers, affirming that legal expenses incurred defending...more

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