News & Analysis as of

Internal Revenue Service Financial Institutions 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.  
Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

Vedder Price on

On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...more

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

Troutman Pepper Locke on

In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Being aggressive on your mistakes could be a bad idea

Many moons ago, I got a call from a bank with a problem. For two decades—yes, twenty years—they had failed to include bonuses as part of plan compensation. The kicker? They were supposed to. This wasn’t a gray area; the plan...more

Vorys, Sater, Seymour and Pease LLP

The Importance of Actively Monitoring S Corporation Compliance

Many banks have elected to be “S Corporations” for tax purposes. This status can provide significant tax benefits to the bank’s shareholders, but it also comes with several ongoing technical requirements. Failure to satisfy...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Cadwalader, Wickersham & Taft LLP

IRS’s Crypto John Doe Summons Expanded While Harper Fights Back

Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more

Freeman Law

What Can the State of Texas Do to Collect State Taxes?

Freeman Law on

So, the Texas Comptroller of Public Accounts (“Comptroller”) says you owe state tax. If the deficiency determination hasn’t yet become final, you still may be able to challenge the underlying tax liability (for more on that,...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights, Issue 9

Top IRS Official Says Marijuana Banking Reform Would Help Feds ‘Get Paid’ - "IRS’s Cassidy Collins talked about the 'special type of collection challenge' that the agency faces when it comes to working with cannabis...more

Foodman CPAs & Advisors

The Tax Gap To Rise To Approximately $7 Trillion

The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed.   In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more

Bowditch & Dewey

Cryptocurrency Tax Update

Bowditch & Dewey on

The IRS continues its campaign against cryptocurrency investors and traders who evade income taxes on currency gains. As we wrote in 2016, the IRS was successful in compelling Coinbase, a large digital currency exchange, to...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

Bradley Arant Boult Cummings LLP

IRS Releases Guidance on Taxability of Identity Protection Services

As companies and governmental entities increasingly do business and store sensitive information in online or cloud-based environments, the risk of improper disclosure continues to grow. The unprecedented breach of the United...more

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