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Income Taxes › Internal Revenue Service › Internal Revenue Code (IRC)

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 -
McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

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The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Baker Donelson

IRS Streamlines 83(b) Election Process with New Online Filing Option

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The Internal Revenue Service (IRS) continued recent improvements to the process for making elections under Section 83(b) of the Internal Revenue Code of 1986 (the Code). Until last year, an 83(b) election was made in a...more

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

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Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Whiteford

Client Alert: How the “One Big Beautiful Bill Act” Impacts Employers, Employees and Contractors

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The recently enacted One Big Beautiful Bill Act (the “Act”) introduces several significant amendments to the Internal Revenue Code (“IRC”) that directly affect U.S. employers and employees. Key provisions—particularly the...more

Cadwalader, Wickersham & Taft LLP

Partnerships Gain CAMT Alternative

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On July 29, the IRS issued interim guidance intended to reduce the compliance burdens associated with applying the corporate alternative minimum tax (“CAMT”) to partnerships.  In so doing, they announced their intention to...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

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Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part IX – Deductibility of Automobile Loan Interest

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In this ninth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that may permit individual taxpayers to deduct the interest incurred with respect to their...more

Pullman & Comley, LLC

Overview of the Tax Provisions in the One Big Beautiful Bill Act

Pullman & Comley, LLC on

On July 4, 2025,, the One Big Beautiful Bill Act (OBBBA) became law.  The Act itself was almost 1,000 pages.  It made many of the provisions of the 2017 Tax Cuts and Jobs Act permanent and included new federal tax provisions....more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

Littler on

In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Whiteford

Employment Law Update: New Overtime Tax Law Increases Employer Recordkeeping Obligation

Whiteford on

The Administration’s “Big Beautiful Bill” includes a new overtime tax provision, broadly described as “No Tax on Overtime.” More accurately, the Bill allows an employee tax deduction of a portion of overtime payments, up to a...more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Holland & Knight LLP

IRS Releases 2025 Inflation Adjustments for Sections 45U, 45V and 45Z

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The IRS on July 21, 2025, released Notice 2025-37, announcing the inflation-adjusted credit amounts for calendar year 2025 applicable to tax credits available under Internal Revenue Code Sections 45U, 45V and 45Z, which were...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Cadwalader, Wickersham & Taft LLP

House Ways and Means to Crypto’s Rescue on Taxes?

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On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more

Hanson Bridgett

IRS Clarifies Income Tax Withholding and Reporting Obligations for Uncashed Retirement Checks

Hanson Bridgett on

When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

Foster Garvey PC on

In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more

Goodwin

Online Filing of Section 83(b) Elections Is Here!

Goodwin on

Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part III – Gambling / Code Section 165(d)

Foster Garvey PC on

In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy of...more

Rivkin Radler LLP

Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?

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The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more

Ballard Spahr LLP

President Trump’s Budget Extends His 2017 Individual Tax Provisions

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President Trump signed into law what is commonly referred to as the One Big Beautiful Bill Act (OBBBA), extending provisions from the Tax Cuts and Jobs Act of 2017 otherwise set to expire at the end of this year. The new...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

It’s Official - No Tax on Tips, No Tax on Overtime Through 2028

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One of President Donald Trump’s 2024 campaign messages was a promise to implement a no-tax-on-tips and no-tax-on-overtime law. On July 3, 2025, the U.S. Congress passed the “One Big Beautiful Bill,” and President Trump signed...more

Schwabe, Williamson & Wyatt PC

U.S. Treasury Announces Tribal Consultation on General Welfare Exclusion Act

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On June 30, 2025, the United States Department of the Treasury announced that it will be holding an online tribal consultation with Alaska Native Corporations on July 29, 2025, from 1:30 pm to 4:30 pm ET, to discuss the...more

Holland & Knight LLP

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

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In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

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Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

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