News & Analysis as of

Internal Revenue Service Disclosure Requirements Tax Liability

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...

Executive Use of Corporate Aircraft: Navigating Tax, SEC Disclosure and Other Key Considerations

Companies are increasingly allowing their chief executive officers and, in certain circumstances, other executives to use corporate jets (which may be chartered flights or fractionally or fully owned aircraft) for personal...more

Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

Allen Barron, Inc. on

What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more

Jones Day

Developments in Crypto Regulation: DeFi Tax Reporting Repeal and SEC Disclosure Guidance

Jones Day on

The Trump administration continues its efforts to relax digital asset regulation, including most recently by exempting decentralized finance ("DeFi") apps and wallets from tax reporting and through Securities and Exchange...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

Freeman Law on

In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Rivkin Radler LLP

Tax Compliance: Self-Assessment, Transparency, and Enforcement

Rivkin Radler LLP on

NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more

Freeman Law

Correction to APA Non-Compliance | IRS Issues Proposed Regulations for Syndicated Conservation Easements

Freeman Law on

On December 6th, the IRS proposed regulations (and comment period for same) that would require participants and promoters of syndicated conservation easement transactions to make certain disclosures relating conservation...more

Freeman Law

Extended Tax Filing Deadline | Commonly Overlooked Tax Disclosures

Freeman Law on

This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more

Oberheiden P.C.

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

Freeman Law

The Art of the Tax Disclosure: How to Avoid Tax Penalties By Disclosing a Return Position

Freeman Law on

There are at least three questions when it comes to IRS tax disclosures: (1) Should a taxpayer disclose; (2) How should a taxpayer disclose; and (3) How much detail should be disclosed? Should a taxpayer simply append a...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

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