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Internal Revenue Service Disclosure Requirements Tax Returns

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.  
Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

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On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

Ropes & Gray LLP

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

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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

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Seward & Kissel LLP

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

Seward & Kissel LLP on

Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Allen Barron, Inc.

When to Consider the IRS Streamlined Procedures

Allen Barron, Inc. on

What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting...more

Venable LLP

Tennessee and Utah Amend Charitable Solicitation Laws: New Filing, Disclosure, and Other Obligations Affect Fundraising Compliance...

Venable LLP on

Tennessee and Utah have revised the scope of their charitable fundraising laws. These changes will affect how and what nonprofit organizations registered to solicit in those states must disclose to state charity regulators....more

Allen Barron, Inc.

Have You Disclosed Offshore Cryptocurrency and NFT Activities to the IRS?

Allen Barron, Inc. on

Have you fully disclosed offshore cryptocurrency and NFT activities to the IRS? Earlier this month, the US Department of Justice announced the indictment of a Texas man for tax returns that were inaccurate, incomplete, or...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

ArentFox Schiff

IRS Loosens, and Tightens, Disclosure of Nonprofit Taxpayer Information

ArentFox Schiff on

On August 16, 2022, the Internal Revenue Service issued a final regulation on its ability to provide state governments with information regarding organizations seeking to become exempt and those already exempt from federal...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

Mayer Brown

The Taxpayer First Act and the Impact on Secondary Market Participants

Mayer Brown on

The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019.  The Act is designed, among other things, to overhaul and modernize...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

Carlton Fields

Domestic Partnership Agreements: Financial Disclosures and Privacy

Carlton Fields on

To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each other prior to signing the agreement. Each partner should disclose to the...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 8

In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more

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