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Internal Revenue Service Compliance

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.  
Proskauer - Employee Benefits & Executive...

FICA Tax: Navigating the Nonqualified Deferred Compensation Special Timing Rule

Compensation is generally subject to federal income tax and FICA tax when compensation is actually paid to an employee. However, nonqualified deferred compensation (NQDC) may be subject to FICA taxation before federal income...more

Allen Barron, Inc.

IRS and State Tax Complications of Offshore Investments

Allen Barron, Inc. on

What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Skadden, Arps, Slate, Meagher & Flom LLP

Taxing Intelligence: AI's Role in Modern Tax Administration

As artificial intelligence has taken center stage across industries, does it also have a place in tax administration? Our latest episode of “GILTI Conscience” explores potential applications of AI in the world of tax,...more

Jackson Walker

Employee Retention Credit (ERC) Changes under the One Big Beautiful Bill Act: Some Disallowances, Six-Year Statute of Limitations...

Jackson Walker on

Many ERC claimants are breathing a sigh of relief given the much toned-down version of the changes to the ERC enacted on July 4, 2025. As enacted, the One Big Beautiful Bill Act (the “OBBBA”) disallows all pending ERC claims...more

Mayer Brown

Changes to IRS Examinations of Large Corporate Taxpayers: A Sea Change or Whistling in the Wind?

Mayer Brown on

On July 23, 2025, the IRS issued guidance on audits of large corporate taxpayers. This guidance falls squarely in line with previous IRS statements at conferences, as well as its prior guidance about making examinations more...more

White & Case LLP

Goodbye to the IRS AOF Information Document Request

White & Case LLP on

On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more

Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Roth Catch-Up Chaos is coming

Plan sponsors and recordkeepers let out a collective sigh of relief when the Roth catch-up contribution requirement under SECURE 2.0 was delayed until 2026. And for good reason—this rule, though well-intentioned, brings with...more

Kelley Drye & Warren LLP

Simplified Option for Correcting Certain Retirement Plan Failures

Earlier this year, the U.S. Department of Labor (“DOL”) amended its Voluntary Fiduciary Compliance Program (“VFCP”) to provide retirement plan sponsors with a simplified option for correcting certain specified prohibited...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

Oberheiden P.C.

5 Key Considerations for Defending Against Low Income Housing Tax Credit (LIHTC) Fraud Allegations

Oberheiden P.C. on

Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more

Foster Swift Collins & Smith

IRS Expands Self-Correction Program: What Plan Sponsors Need to Know About the Interim Guidance

The IRS has made it easier for retirement plan sponsors to fix common plan mistakes without going through a formal filing process. Under interim guidance in Notice 2023-43, sponsors can now correct a broader range of errors...more

White & Case LLP

Tax-Exempt Organizations Should Prepare Now For An IRS Tax Audit

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It is an uncertain time to be a tax-exempt public charity or private foundation. The federal government has recently scrutinized certain tax-exempt organizations (see here), and draft congressional legislation proposed a tax...more

Bass, Berry & Sims PLC

Reminder – Annual Deadline (July 31) to Report and Pay PCORI Fee is Approaching (UPDATED)

The annual filing (and fee payment) for applicable self-insured health plans and specified health insurance policies used to fund the Patient-Centered Outcomes Research Institute (PCORI fee) is due by Thursday, July 31, 2025....more

Farella Braun + Martel LLP

REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations

Welcome to EO Radio Show – Your Nonprofit Legal Resource. Many nonprofits today are worried about recent federal actions that may bring governmental scrutiny to their stated charitable mission and activities, such as audits,...more

McDermott Will & Schulte

Executive Order Implications for 501(c)(3) Status

Media reports about the Trump administration’s desire to revoke the tax-exempt status of prominent charitable organizations recently jolted the United States’s nonprofit community with anxiety over the impact potential...more

Foster Swift Collins & Smith

Navigating Long-Term Part-Time Employee Eligibility Rules for 401(k) Plans

The landscape of retirement plan eligibility is shifting, and plan sponsors need to prepare for key compliance changes affecting long-term part-time (“LTPT”) employees. These new rules, mandated by the SECURE Act of 2019 and...more

Cadwalader, Wickersham & Taft LLP

Comments Would Limit Circular 230 Proposed Regulations

On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Lowenstein Sandler LLP

SEC Clarifies Accredited Investor Verification for Rule 506(c) Offerings

Lowenstein Sandler LLP on

The Securities Act of 1933, as amended (Securities Act), requires that any offer or sale of securities in the United States must either be registered with the SEC or qualify for an exemption to registration thereunder....more

Foley & Lardner LLP

Mandatory Roth Catch-up: More than Meets the Eye

Foley & Lardner LLP on

In January, the Department of the Treasury (“Treasury”) and Internal Revenue Service (IRS) issued proposed regulations on the catch-up contribution provisions under the SECURE 2.0 Act of 2022 (“SECURE 2.0”). While the...more

Rivkin Radler LLP

Transferring the Family Business To A Private Foundation? Are You Sure About That?

Rivkin Radler LLP on

Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more

Vinson & Elkins LLP

Congress Begins Taking Action to Nullify Biden-Era Tax Regulations

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The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more

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