News & Analysis as of

Internal Revenue Service Final Rules Tax Deductions

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.  
Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

Williams Mullen on

On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Lowenstein Sandler LLP

Paycheck Protection Program: FAQs For Microbusinesses - UPDATED March 2021 #2

Lowenstein Sandler LLP on

On December 27, the President signed into law the Consolidated Appropriations Act, 2021. The Act includes a roughly $900 billion COVID-19 relief package, known as the “Economic Aid to Hard-Hit Small Businesses, Nonprofits and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more

WilmerHale

Final Section 162(f) Regulations Liberalize Opportunities to Deduct Disgorgement and Other Payments Made in Government...

WilmerHale on

On January 12, 2021, the Internal Revenue Service (IRS) and the Treasury Department released final regulations governing the deductibility of certain fines, penalties and other amounts paid to, or at the direction of, a...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Final Regulations Regarding Certain Employee Remuneration in Excess of $1 Million Under Section 162(m) of the Code

Section 162(m) of the Internal Revenue Code of 1986 (as amended, the “Code”) imposes a $1 million deductibility limit on compensation paid by “publicly held corporations” to “covered employees.” As reported in our previous...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

White and Williams LLP

IRS Ends Certain State Workarounds to SALT Deduction

White and Williams LLP on

On June 11, 2019, the IRS issued final regulations that will prohibit taxpayers from using state programs to sidestep state and local tax (SALT) deduction limitations. The SALT deduction, which has been in existence for over...more

Proskauer - Tax Talks

“Passthrough Deduction” Regulations Finalized

Proskauer - Tax Talks on

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more

Womble Bond Dickinson

How to Make Charitable Contribution Deductions Vanish in to Thin Air – a Review of the Charitable Contribution Substantiation...

Womble Bond Dickinson on

On July 27, 2018, the Treasury issued final regulations regarding substantiation requirements for cash and noncash charitable contributions. T.D. 9836 (2018). The final Regulations reflect amendments to Section 170 of the...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Assisted And Senior Living Facilities

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Latham & Watkins LLP

Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Latham & Watkins LLP on

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

McDermott Will & Emery

Weekly IRS Roundup January 14 – 18, 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 January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the...more

Farella Braun + Martel LLP

Protect Your Charitable Deduction Recently Issued Final Regulations Affect Substantiation Requirements

Charitable donors expecting an income tax deduction must obtain, maintain, and in some cases provide to the IRS specific documentation to substantiate their donation. Donors should pay careful attention to these...more

Goulston & Storrs PC

IRS Addresses Interaction of Performance Compensation and $1M Compensation Deduction Cap

Goulston & Storrs PC on

The IRS recently issued final regulations under Section 162(m), which limits a public company’s deduction of executive compensation in excess of $1M.  The Section 162(m) limits do not apply to performance-based compensation...more

Snell & Wilmer

IRS Releases Clarifying 162(m) Regulations

Snell & Wilmer on

The IRS recently released final regulations clarifying two aspects of the “performance-based compensation” exception to the $1,000,000 limit on deductible compensation paid to covered employees under Section 162(m) of the...more

Fenwick & West LLP

Executive Compensation Alert: IRS Releases Final Section 162(m) Regulations

Fenwick & West LLP on

Background - Section 162(m) of the Internal Revenue Code (the “Code”) denies a tax deduction to a public company if the compensation paid to its chief executive officer and three other highest compensated officers...more

Troutman Pepper Locke

Locke Lord QuickStudy: IRS Clarifies Performance-Based Compensation Exception Under Code Section 162(m)

Troutman Pepper Locke on

On March 31, 2015, the Internal Revenue Service (IRS) published final regulations under Section 162(m) of the Internal Revenue Code (the Code). Code Section 162(m) disallows a deduction by any publicly-held corporation for...more

McDermott Will & Emery

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more

Mintz - Employment, Labor & Benefits...

IRS Releases Final Regulations Clarifying 162(m) Limitation on Compensation

Section 162(m) of the Internal Revenue Code precludes the deduction by public companies for compensation paid to certain covered employees in excess of $1,000,000 in any taxable year. This limitation on deduction does not...more

Williams Mullen

Final Regulations Issued For Investment Advisory Fees and Other Costs Incurred By Trusts and Estates Subject to the 2-Percent...

Williams Mullen on

On May 8, 2014, the Internal Revenue Service published final Treasury Regulations, §1.67-4, prescribing when costs incurred by estates or nongrantor trusts are subject to the 2-percent floor for miscellaneous itemized...more

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