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Internal Revenue Service Tax Planning Financial Services Industry

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.  
Vinson & Elkins LLP

Congress Begins Taking Action to Nullify Biden-Era Tax Regulations

Vinson & Elkins LLP on

The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more

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

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

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Carlton Fields

IRS Clarifies Application of Required Minimum Distribution Rules to Inherited Retirement Accounts

Carlton Fields on

The Secure Act, passed in 2019 and updated in 2022, made significant changes to the required minimum distribution (RMD) rules applicable to qualified retirement plans, IRAs, 403(b) plans, and other eligible deferred...more

Stinson - Benefits Notes Blog

Annual Limits on Qualified Plans for 2024

On November 1, 2023, the Internal Revenue Service (IRS) released Notice 2023-75, which sets forth the 2024 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

Pullman & Comley - Labor, Employment and...

No Extended Secure Act Amendment Period for Section 457(b) Plans Sponsored by Tax-Exempt Entities: Amendments Due December 31,...

Section 457(b) Plans provided by Tax-Exempt employers for their highly compensated employees and/or a select group of management employees (“Tax-Exempt 457(b) Plans”) are subject to required minimum distribution rules under...more

Foodman CPAs & Advisors

Preguntas que las IF deberían hacer a los Proveedores de Servicios Externos de FATCA y CRS

Guía de la OCDE ofrece a las instituciones financieras asesoramiento sobre la contratación de organizaciones de servicios externos para gestionar el cumplimiento....more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Kohrman Jackson & Krantz LLP

New Tax Rule Changes Reporting Requirements For Venmo, Paypal, Cash App

A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Morgan Lewis

IRS Extends Temporary Use of Electronic and Digital Signatures for Certain IRS Forms Until December 31, 2021

Morgan Lewis on

The US Internal Revenue Service (IRS) extended its temporary approval of accepting digital signatures on certain IRS forms until December 31, 2021 (see Memorandum NHQ-10-1220-000, the Memorandum). This Memorandum has also...more

Morgan Lewis

IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors

Morgan Lewis on

The Internal Revenue Service (IRS) issued Notice 2021-10 on January 19, which extends relief to Qualified Opportunity Funds (QOFs) and their investors as a response to continued challenges brought on by the COVID-19 pandemic....more

Morgan Lewis

IRS Approves Temporary Use of Digital Signatures for Certain Forms

Morgan Lewis on

The US Internal Revenue Service (IRS) issued news release IR-2020-194 on August 28, approving the temporary use of digital signatures for certain IRS forms that must be filed with the IRS manually. ...more

Foodman CPAs & Advisors

What do you do if you are a Financial Institution with COVID-19 Loan Accommodations near the end?

On August 3, 2020, the Federal Financial Institutions Examination Council (FFIEC)  issued a Joint Statement on Additional Loan Accommodations Related to COVID-19 regarding loans  that are near the end of an initial loan...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

Stinson LLP on

On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Morgan Lewis

IRS Issues Proposed Regulations on Carried Interests

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more

Morgan Lewis

IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations

Morgan Lewis on

The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more

Morgan Lewis

IRS Gearing Up for More Exempt Organization Examinations

Morgan Lewis on

Tax-exempt organizations should be aware that the Internal Revenue Service plans to add more focus—and more personnel—toward its examination efforts, including new strategies to address potential noncompliance....more

Foodman CPAs & Advisors

Banquero Irá a la Cárcel por FATCA

El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more

Foodman CPAs & Advisors

Banker will go to jail over FATCA

On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more

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