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Internal Revenue Service

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DLA Piper

REIT Tax News - June 2025

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On May 22, 2025, the House of Representatives passed a tax bill (House Tax Bill) that proposes to make permanent – and increase – the section 199A deduction for ordinary REIT dividends to 23 percent. This change would reduce...more

McDermott Will & Emery

IRS Roundup May 15 – June 2, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | Special Edition for June 2025

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In this Court Rips edition of the buzz: IRC §280E limits the ERC for cannabis company - Canna Provisions case is dismissed (again) by Appeals Court....more

White & Case LLP

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

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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

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for the Real Estate Industry

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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

Troutman Pepper Locke

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

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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

Guidepost Solutions LLC

Navigating IRS Code Section 132: Independent Security Studies for Executives

In the past five months, we have seen a greater number of requests for the Independent Security Study than in the past five years combined. What is driving this surge? Greater awareness by boards as to the importance of...more

Bricker Graydon LLP

Have You Considered How a Reduction in Force Impacts Your 401(k) Plan?

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As businesses continue to respond to recent shifts in the U.S. economy, some employers have had to make the challenging decision to implement cost-cutting measures and reductions to their workforce....more

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

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

Woodruff Sawyer

REMINDER: PCORI Fees Due By July 31, 2025

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Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2025 deadline for paying fees that fund the Patient-Centered Outcomes...more

WilmerHale

Court Decision on Limited Partner Exception to Self-Employment Tax

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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

Proskauer Rose LLP

Wealth Management Update - June 2025

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The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more

Seward & Kissel LLP

Proposed Tax on Certain Outbound Remittances

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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

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

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The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Cooley LLP

Trump’s Initiative to Revoke Harvard’s Tax-Exempt Status: Implications for Higher Education

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President Donald Trump has repeatedly threatened to strip the tax-exempt status from colleges and universities. Most recently, on May 2, Trump announced in a social media post, “We are going to be taking away Harvard’s Tax...more

Kohrman Jackson & Krantz LLP

Navigating Interest Income in 1031 Exchanges: Strategic Considerations for Tax Deferral

As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more

Holland & Knight LLP

IRS Proposes Key Changes to Roth Catch-Up Contributions Under SECURE 2.0

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The IRS has issued proposed regulations that clarify and implement catch-up contribution changes introduced by the SECURE 2.0 Act of 2022. Although these changes affect various forms of retirement plans, including 401(k),...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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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

Allen Barron, Inc.

Tax Developments for US Expatriates

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There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more

Cadwalader, Wickersham & Taft LLP

Another Appeal Adds Fuel to the Limited Partner SECA Tax Debate

Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Gray Reed

Balancing Privacy and Tax Enforcement in the Digital Age

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The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek financial information on thousands of...more

Cadwalader, Wickersham & Taft LLP

Where’s Waldo? Budget and Crypto Bills Silent on Crypto Tax

The House’s recent budget bill includes significant tax legislation; however, it does not include any crypto tax provisions. Additionally, the GENIUS Act, which recently moved forward in the Senate and would provide a...more

Holland & Knight LLP

Eyes on Energy Tax: IRS Releases 2025 Section 45 Production Tax Credit Amounts

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The IRS on May 23, 2025, released 2025 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code. The guidance provides that: Section 45 allows a renewable energy PTC for generating electricity from...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - May 2025

The May Monthly Minute brings you up-to-date on mental health parity enforcement relief, as well as smoker surcharge and prohibited transaction litigation. Nonenforcement of 2024 Mental Health Parity Regulations - Earlier...more

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