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Internal Revenue Service Proposed Rules Tax Planning

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.  
Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Roth Mandate Mess: AICPA Asks for Clarity on SECURE 2.0 Catch-Up Contributions

When Congress passes sweeping retirement legislation, the details often come later—and those details usually come in the form of regulatory spaghetti that plan sponsors and administrators are left to untangle. Case in point:...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

Sullivan & Worcester on

On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...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

Cadwalader, Wickersham & Taft LLP

New York State Bar Association Tax Section Proposes Withdrawal of Proposed Spin-Off Regulations

On March 17, the Tax Section of the New York State Bar Association (the “Tax Section”) released a report on the proposed regulations on corporate spin-offs and reorganizations that were issued in January. As we discussed...more

Burr & Forman

Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare

Burr & Forman on

Join Carlton Hilson and Amy Jordan Wilkes as they discuss the recent proposals that aim to eliminate federal taxes on overtime pay and tips and what this means for employers....more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Proposes New Rules to Implement the Expanded $1 Million Limit on Deductible Pay for Publicly Held Corporations

New proposed regulations under Section 162(m) of the Internal Revenue Code would further limit deductibility of executive compensation paid by a publicly held corporation....more

Freeman Law

Treasury Issues Final Digital Asset Sourcing Regs and Proposed Cloud Transaction Sourcing Regs

Freeman Law on

On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions. Why is Source Important? While U.S. persons generally are...more

Seyfarth Shaw LLP

Catching-Up on Catch-Up Contribution Changes

Seyfarth Shaw LLP on

New proposed regulations issued by The Department of Treasury and IRS provide guidance on the provisions related to catch-up contributions that were included under SECURE 2.0 Act of 2022 (“SECURE 2.0”)....more

McDermott Will & Schulte

IRS Roundup January 6 – 10, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025....more

Eversheds Sutherland (US) LLP

Time to catch-up on your New Year’s regulations: IRS “super” and Roth guidance

On January 10, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations related to two new catch-up contribution provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0): (1) the...more

Seyfarth Shaw LLP

How Now, High Five? IRS Issues Proposed Regulations for the Expanded Definition of “Covered Employee” Under Section 162(m) that...

Seyfarth Shaw LLP on

On January 16, 2025, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code of 1986 (the “Code”), which limit the amount of compensation a publicly held corporation may deduct for wages paid to...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...more

McAfee & Taft

New year = New proposed rules impacting retirement plans

McAfee & Taft on

The Internal Revenue Service has been busy. On Friday, January 10, 2025, the IRS issued several notices of proposed rulemaking impacting qualified retirement plans. One set of proposed rules adds to the SECURE 2.0 requirement...more

DarrowEverett LLP

How Will New Congress Impact Tax and Estate Planning Strategies?

DarrowEverett LLP on

With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Stark & Stark

The Internal Revenue Service (IRS) Issues Proposed Minimum Distribution Rules

Stark & Stark on

The Internal Revenue Service (IRS) recently issued much anticipated proposed regulations that clarify and revise some of the required minimum distribution (RMD) rules for qualified plans (i.e. 401ks, 403bs, etc.) and...more

McDermott Will & Schulte

Six Takeaways: Utilization and Structuring For Section 45Q Carbon Capture Credits

The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more

McDermott Will & Schulte

[Webinar] Utilization and Structuring For Section 45Q Carbon Capture Credits - June 11th, 12:30 pm EST

The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more

McDermott Will & Schulte

Weekly IRS Roundup September 2 – 6, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

Ward and Smith, P.A.

All You Need to Know About Qualified Opportunity Zones. For Now.

Ward and Smith, P.A. on

Interest in Qualified Opportunity Zones ("QOZs") has increased since October 29, 2018, when the Department of the Treasury and the Internal Revenue Service published the proposed rules relating to QOZs in the Federal...more

Brooks Pierce

Investing In Qualified Opportunity Funds

Brooks Pierce on

The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more

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