News & Analysis as of

Internal Revenue Service Tax Liability Withholding Tax

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.  
Troutman Pepper Locke

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

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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

DLA Piper

Tax Considerations for Public Company Equity Incentive Awards

DLA Piper on

This is the third part of a series covering certain securities law, corporate governance, and tax considerations related to stock options and restricted stock unit (RSU) awards granted by public companies....more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Cadwalader, Wickersham & Taft LLP

Aftermath of YA Global: A Call for Procedural Clarity for Section 1446 Withholding Tax

The New York State Bar Association Tax Section (the “NYSBA”) has asked the government to provide guidance on the procedure for filing a protective return in respect of withholding tax in response to YA Global Investments, LP...more

Bowditch & Dewey

Update Your 2024 Tax Withholding to Avoid Year-End Surprises

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Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Freeman Law

International Tax Withholding | Chapter 3 of the Internal Revenue Code

Freeman Law on

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Bowditch & Dewey

Update Your Tax Withholdings to Avoid Year-End Surprises

Bowditch & Dewey on

During the 2022 tax filing season, many taxpayers had an unpleasant surprise when they filed their tax return and found out they were getting a much smaller refund than they were expecting, or worse, had a balance due....more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

Rivkin Radler LLP on

Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Freeman Law

Withholding Agents and FDAP Income

Freeman Law on

Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more

Freeman Law

What is an IRS Notice of Deficiency?

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Ordinarily, taxpayers file their income tax returns each year with the IRS and hear nothing more. Rather, the Internal Revenue Service (“IRS”) simply processes the tax return, assesses the reported amount of tax due, and...more

Foodman CPAs & Advisors

What is Backup Withholding Tax and Who Has to Pay It?

When it comes to taxes, mistakes can cost you more than money. That’s especially true with Federal backup withholding taxes. In simplest terms, 24 percent backup withholding is demanded of both payers and payees who either...more

Rivkin Radler LLP

Thinking About ‘Avoiding’ NY Tax Increases? Then Think About The False Claims Act

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According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more

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

Taxing Times - April 2021

Male Escort Gets 21 Months In Prison For Tax Case - He lied on his tax returns, resulting in a tax loss to the IRS of $278,325. A male escort who lied to the IRS about his income was sentenced to 21 months in prison and...more

Freeman Law

In the Matter of James and Simona Quezada v. Internal Revenue Service – The Fifth Circuit and the Discharge of Taxes in Bankruptcy

Freeman Law on

The dischargeability of and the ability to collect taxes by the IRS in a consumer bankruptcy case often turn on the issue of whether and when the taxpayer filed the relevant returns, thereby determining when the statute of...more

Foodman CPAs & Advisors

¿Retención FACTA errónea?

Foodman CPAs & Advisors on

¿Qué sucede si un agente de retención de los EE. UU. de una institución financiera extranjera (FFI) aplica erróneamente una retención del capítulo 4 de FATCA del Código de Rentas Internas (IRC) del 30% a un pago a la FFI?...more

Hogan Lovells

Final regulations – U.S. withholding tax on transfers of partnership interests

Hogan Lovells on

Since 2018, the buyers, sellers, and partnerships engaging in secondary and other transactions involving partnership interest transfers have been navigating complicated U.S. tax and related withholding obligations that apply...more

McDermott Will & Schulte

Weekly IRS Roundup October 5 – October 9, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020... October 7, 2020: The IRS published final regulations...more

Foster Garvey PC

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

Foster Garvey PC on

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

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

McDermott Will & Schulte

Weekly IRS Roundup September 9 – 13, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more

Troutman Pepper Locke

Transferring Partnership Interests: Buyer Beware of Withholding Obligations, Seller Beware of Tax Liability - Tax Update Volume...

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The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more

Foodman CPAs & Advisors

Are you at Risk for a Tax Time Surprise?

There will be Taxpayers whose 2018 federal income tax withholding unexpectedly falls short of their tax liability for Tax Year 2018. ...more

Proskauer - Tax Talks

Tax Reform – I.R.S. Updates Withholding Tax Guidance on Sales of Partnership Interests

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On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more

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