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Internal Revenue Service Taxation

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.  
Eversheds Sutherland (US) LLP

Entering the Digital (Asset) Age: White House Report Recommends Changes to the Taxation of Digital Assets

The President’s Working Group on Digital Asset Markets recently issued a detailed report, titled “Strengthening American Leadership in Digital Financial Technology,” recommending regulatory and legislative proposals to...more

Cadwalader, Wickersham & Taft LLP

Trump’s Crypto White Paper Talks Tax!

On July 30, 2025, the Trump Administration issued an expansive report on the crypto industry (the “White Paper”), describing the digital asset landscape and outlining the contours of a legislative and regulatory framework....more

Fox Rothschild LLP

DOJ Tax Division Leader Departs Amid Large-Scale Reorganization

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The head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who served as acting deputy assistant attorney...more

Fox Rothschild LLP

IRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two Months

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On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax agency’s 162-year...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

Frost Brown Todd on

Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Clark Hill PLC

EIN retention in healthcare M&A: How F-Reorganizations can preserve regulatory and tax continuity

Clark Hill PLC on

Often in healthcare transactions, retaining a federal Employer Identification Number (“EIN”) after an acquisition or restructuring is essential to the continuity of operations, regulatory compliance, and preservation of key...more

Proskauer - Tax Talks

Eighth Circuit Affirms Mayo Clinic’s “Educational Organization” Status and UBTI Refund

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On July 25, 2025, the U.S. Court of Appeals for the Eighth Circuit affirmed the District Court decision holding that the Mayo Clinic is entitled to an $11.5 million refund of certain unrelated business income taxes imposed on...more

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

Littler on

In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

Eversheds Sutherland (US) LLP

IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs

On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #3

Speaker Johnson Kicks Off Discussions for Reconciliation 2.0: House Republicans are laying the groundwork for a second reconciliation bill this fall that aims in part to revive key provisions excluded from the One, Big,...more

Fox Rothschild LLP

IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement

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The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more

DarrowEverett LLP

The Earnout Equation: Tax Tips for Both Buyers and Sellers

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Earnouts are a form of contingent consideration that the buyer of a business pays to the seller in the period following the acquisition, based on the business achieving various financial metrics related to its performance...more

Mayer Brown

What the New Remittance Transfer Excise Tax Means for Businesses

Mayer Brown on

OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX - Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

ASKramer Law on

At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Royer Cooper Cohen Braunfeld LLC

One Big Beautiful Bill Expands Key Tax Incentives Including Section 1202 Qualified Small Business Stock and Qualified Opportunity...

The reconciliation bill, known as the “One Big Beautiful Bill” (the “BBB”), was recently signed into law on July 4th. The BBB, among many other things, made significant changes in tax law, building on the foundations created...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #2

Passthrough Deduction Eyed for Bigger Boost in Future Bill: House Republicans are weighing the possibility of a second major tax package following the recent enactment of their One, Big, Beautiful Bill Act (OBBBA, Public Law...more

Cadwalader, Wickersham & Taft LLP

House Ways and Means to Crypto’s Rescue on Taxes?

On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more

Hanson Bridgett

IRS Clarifies Income Tax Withholding and Reporting Obligations for Uncashed Retirement Checks

Hanson Bridgett on

When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more

Proskauer - Employee Benefits & Executive...

IRS Clarifies that Failure to Cash Checks Does Not Affect Withholding or Reporting

Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed...more

Clark Hill PLC

Crypto taxes take center stage

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On July 16, the House Ways and Means Oversight Subcommittee held a hearing titled Making America the Crypto Capital of the World: Ensuring Digital Asset Policy Built for the 21st Century. The hearing confronted the widening...more

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