News & Analysis as of

Internal Revenue Service Reporting Requirements 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.  
Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

Husch Blackwell LLP on

One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

Hone Maxwell on

Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Allen Barron, Inc.

Tax Developments for US Expatriates

Allen Barron, Inc. on

There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....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

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

Ballard Spahr LLP on

On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...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

Amundsen Davis LLC

No Tax on Tips Act: How Taxpayers Can Prepare

Amundsen Davis LLC on

Tipping has been part of the modern-day American restaurant experience for decades. Like most forms of income, these tips are taxable and subject to income tax. But what if this income was free from income tax liability?...more

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

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

2024 Crypto Tax Year in Review

The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...more

Seward & Kissel LLP

New Administration Action on Cryptocurrency Tax Regulations

Seward & Kissel LLP on

The Seward & Kissel Tax Group has collected some data and intelligence about what crypto tax changes we may see this year. President Trump aims to assess and revive cryptocurrency regulations via executive order, Congress...more

Verrill

Solo 401(k) Plans: A Quick Fix-It Guide

Verrill on

“Solo 401(k)” is a marketing term used for a 401(k) plan that is adopted by a sole proprietor or an incorporated business with no employees other than the owner. These plans offer a greater retirement savings opportunity...more

Allen Barron, Inc.

Will You Recognize the Form 1099-K When You Receive it This Year?

Allen Barron, Inc. on

Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year?  A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more

Offit Kurman

Not Realizing the True Value of “Stuff”

Offit Kurman on

For federal estate and gift tax purposes, transfers are valued at the “fair market value” of the asset on the date of transfer. One of the more common estate tax audit issues is the failure to properly report the value of...more

Littler

Puerto Rico Department of the Treasury Announces 2025 Limits on Qualified Retirement Plans

Littler on

On January 23, 2025, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the applicable 2024 limits for Puerto Rico qualified retirement plans. Pursuant to...more

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Seyfarth Shaw LLP

IRS Clarifies the Federal Income and Employment Tax Treatment of Contributions to and Benefits Paid from State Paid Family and...

Seyfarth Shaw LLP on

As mandatory State paid family leave and paid family and medical leave (collectively “PFML”) programs have significantly expanded and proliferated in recent years, participating employers and employees have been faced with a...more

Keating Muething & Klekamp PLL

Sale of QSBS and Installment Sale Reporting

In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more

McDermott Will & Emery

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

McDermott Will & Emery on

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Littler

IRS Updates Guidance on Section 530 and Worker Status Issues

Littler on

The Internal Revenue Service has released new guidance, Rev. Rul. 2025-3, clarifying the application of Section 530 of the Revenue Act of 1978, Section 3509 of the Internal Revenue Code (IRC), and Section 7436 of the IRC in...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

Jones Day on

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

McDermott Will & Emery

IRS Roundup January 6 – 10, 2025

McDermott Will & Emery on

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

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

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