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Internal Revenue Service Tax Deferral Income Taxes

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.  
Gerald Nowotny - Law Office of Gerald R....

Pra Dizer Adeus (To Say Goodbye) – A Homage to Sergio Mendes and a Little Bit About Tax Planning for PPLI for Trial Lawyers

Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more

Williams Mullen

[Event] 2024 Fall Tax Forum - November 20th, Richmond, VA

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Join Williams Mullen attorneys for our Fall Tax Forum on Wednesday, November 20th, where our speakers will present on certain federal income tax issues with respect to real property transactions including 1031 exchanges, drop...more

Fisher Phillips

2024 Employee Benefit Limits Plus 6 Best Practices for Employers

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Get Ready For The New Year Ahead - Employees can contribute more pre-tax dollars next year to their retirement savings accounts, including 401(k) and 403(b) plans, according to an IRS announcement made on November 1. Your...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

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It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

McDermott Will & Schulte

Weekly IRS Roundup December 5 – December 9, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Oberheiden P.C.

Can You Defer Taxes on Your Crypto Investments? Ten Tips for What You Need to Know

Oberheiden P.C. on

U.S. taxpayers have an obligation to both report their cryptocurrency transactions to the IRS and pay taxes on it. Individuals who hold on to their cryptocurrencies as an investment are subject to short- and long-term capital...more

McDermott Will & Schulte

Weekly IRS Roundup December 13 – December 17, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 13, 2021 – December 17, 2021. December 13, 2021: The IRS published a memorandum...more

McDermott Will & Schulte

The 90 Percent Test

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Fenwick & West LLP

Section 987 Practice Unit Reflects a Permissive Attitude Towards Different Methods of Branch Currency Translation

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A few weeks ago, the IRS released a new “practice unit” providing training for its examiners on translation of foreign currency gains and losses of branches (so-called qualified business units, or QBU) under §987....more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

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Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

Stinson LLP

IRS Issues Final Carried Interest Regulations

Stinson LLP on

The tax treatment of carried interests was changed with the enactment of Section 1061 of the Internal Revenue Code as part of the 2017 Tax Cuts and Jobs Act. After issuing proposed regulations last summer, the Internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more

Bowditch & Dewey

2020 End of Year Tax Planning for Businesses

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As the 2020 year draws to a close, businesses should review the tax-related provisions adopted in the CARES Act and related IRS guidance with their tax advisers: EMPLOYER REFUNDABLE CREDIT AND PAYROLL TAX DEFERRAL: -...more

Foley & Lardner LLP

Speculation on the Content and Timing of Potential Tax Law Changes in 2021 and 2022

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The November 3 election may have dramatic impacts on the income and estate tax laws. These changes could become effective as early as January 1, 2021. Of course, a big uncertainty is the outcome of the election, and whether...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Foster Garvey PC

Potential Payroll Tax Deferral Is Available – Employers Must Understand the Program and Use Extreme Caution Before Blindly Jumping...

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On August 8, 2020, President Trump issued an executive order, directing the U.S. Treasury to grant employers the ability to defer the withholding, deposit and payment of certain payroll taxes as further COVID-19 tax relief....more

Bowditch & Dewey

IRS issues guidance on Social Security tax deferral

Bowditch & Dewey on

On August 28, the IRS issued Notice 2020-65 to provide guidance on the President’s decision to allow deferral of the employee portion of Social Security taxes owing for the rest of 2020 for employees earning up to $104,000...more

Partridge Snow & Hahn LLP

Employers Have Little Incentive to Implement Social Security Tax Deferral Under New IRS Released Guidance

On Friday August 28th the IRS issued limited guidance on the payroll tax deferral that was part of President Trump’s August 8th executive order. Under IRS Notice 2020-65 (the “Notice”), employers are not required to withhold...more

Farella Braun + Martel LLP

Guidance on Directive to Defer Payroll Tax Obligations Leaves Unanswered Questions

On August 8, 2020, the President directed the Secretary of the Treasury to authorize the deferment of certain payroll tax withholding, depositing, and payment obligations otherwise incurred on wages and compensation paid...more

Eversheds Sutherland (US) LLP

“But wait, there’s more.” – Rev. Proc. 2020-39 provides guidance on the proper treatment of excess deferred taxes, and other...

On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more

Bowditch & Dewey

IRS Provides More Flexibility for Qualified Opportunity Funds in the Wake of COVID Crisis

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In the wake of the COVID Crisis, on June 4, 2020, the IRS issued Notice 2020-39. The Notice provides much-needed relief for taxpayers investing or considering investing in Qualified Opportunity Funds (“QOFs”). Under...more

McDermott Will & Schulte

IRS Significantly Expands COVID-19 Tax Deferral Relief

On March 20, 2020, the Internal Revenue Service expanded its relief for taxpayers in light of the Coronavirus (COVID-19) pandemic. All federal income tax payments and federal income tax returns that were due April 15, 2020,...more

Amundsen Davis LLC

Tax Filing Update

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On March 20, 2020, Treasury Secretary Steven Mnuchin tweeted that this year’s income tax return filing deadline is extended from April 15, 2020 to July 15, 2020. President Trump reiterated the filing extension in a press...more

Foster Garvey PC

Positive Tax News Keeps Rolling In – Treasury Provides Expanded Tax Relief With Notice 2020-18

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Thursday, March 19th, I reported that the U.S. Department of the Treasury (“Treasury”) issued Notice 2020-17, extending the due date for payment of federal income taxes from April 15, 2020 to July 15, 2020, because of the...more

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