News & Analysis as of

Internal Revenue Code (IRC) Income Taxes Tax Deferral

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

Mayer Brown on

Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

Bowditch & Dewey on

As the 2020 year draws to a close, businesses should review the tax-related provisions adopted in the CARES Act and related IRS guidance with their tax advisers: EMPLOYER REFUNDABLE CREDIT AND PAYROLL TAX DEFERRAL: -...more

Foster Garvey PC

Potential Payroll Tax Deferral Is Available – Employers Must Understand the Program and Use Extreme Caution Before Blindly Jumping...

Foster Garvey PC on

On August 8, 2020, President Trump issued an executive order, directing the U.S. Treasury to grant employers the ability to defer the withholding, deposit and payment of certain payroll taxes as further COVID-19 tax relief....more

Partridge Snow & Hahn LLP

Employers Have Little Incentive to Implement Social Security Tax Deferral Under New IRS Released Guidance

On Friday August 28th the IRS issued limited guidance on the payroll tax deferral that was part of President Trump’s August 8th executive order. Under IRS Notice 2020-65 (the “Notice”), employers are not required to withhold...more

Farella Braun + Martel LLP

Guidance on Directive to Defer Payroll Tax Obligations Leaves Unanswered Questions

On August 8, 2020, the President directed the Secretary of the Treasury to authorize the deferment of certain payroll tax withholding, depositing, and payment obligations otherwise incurred on wages and compensation paid...more

Bowditch & Dewey

Social Security Taxes Could Be Deferred for the Rest of 2020

Bowditch & Dewey on

Under the CARES Act passed on March 27, 2020, Congress allowed employers and self-employed workers to defer payment of their portion of Social Security taxes that will accrue between March 27 and December 31, 2020. Fifty...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Eversheds Sutherland (US) LLP

Where there’s smoke there’s fire? IRS simplifies income deferral rules with issuance of final regulations to repeal Treas. Reg. §...

On July 11, 2019, the Internal Revenue Service (Service) and Department of Treasury (Treasury) issued final regulations to remove Treas. Reg. § 1.451-5, which allowed taxpayers to delay reporting income with respect to...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

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There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

White & Case LLP

IRS Issues Guidance on the Deferral of Income from Private Corporation Stock Options and Restricted Stock Units

White & Case LLP on

On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law. The Act added a new Section 83(i) to the Internal Revenue Code of 1986, as amended (the "Code"), pursuant to which certain employees of eligible...more

Harris Beach Murtha PLLC

IRS Issues Initial Guidance on Deferral Option for Qualified Equity Grants

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act ("TCJA") into law. One of the lesser publicized changes enacted by the TCJA was the introduction of new Internal Revenue Code ("Code") Section 83(i),...more

Holland & Hart - Employers' Lawyers

To Be or Not To Be … Subject to the New Section 83(i) Deferral Process - IRS Issues New Guidance

The Internal Revenue Service issued guidance on a tax law change that permits the deferral of income tax on equity awards in private companies. Section 83(i) of the Internal Revenue Code was included in the 2017 Tax Cuts and...more

Morgan Lewis

New US Tax Law Provides Tax Deferral Opportunity for Certain Private Company Equity Grants

Morgan Lewis on

The adoption of Internal Revenue Code Section 83(i) under recent US tax reform will allow certain private company employees to defer federal income tax on eligible stock options and restricted stock units for up to five years...more

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