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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more
At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more
On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain...more
The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more
On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more
On January 10, 2025, the Treasury Department and the Internal Revenue Service issued Proposed Regulations on the automatic enrollment requirements introduced by SECURE 2.0. The Proposed Regulations incorporate and expand...more
New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more
The IRS and Treasury Department recently issued proposed regulations addressing the mandatory automatic enrollment provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0). The proposed regulations generally adopt the...more
Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more
On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more
Proposed legislation introduced in the US Senate last week would deny tax-exempt status to certain organizations that support undocumented immigrants. The legislation would change the eligibility requirements for 501(c)(3)...more
The Internal Revenue Service (IRS) issued proposed regulations providing guidance on how to interpret and implement changes to "catch-up" contributions made by the SECURE 2.0 Act of 2022 (SECURE 2.0). The regulations mainly...more
The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more
Background - Many defined contribution plans are designed to permit participants to take advantage of an increased employee contribution limit starting the year they turn 50....more
Changes effective starting on January 1, 2027 - In the last few days preceding President Donald Trump’s inauguration, the IRS under the Biden administration proposed regulations to implement amendments to Internal Revenue...more
On January 14, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations (Proposed Regulations) relating to the expansion of the definition of “covered employees” under Internal Revenue...more
The Internal Revenue Service (“IRS”) issued proposed regulations regarding the provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) that relate to catch-up contributions....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more
On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more
On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more
In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more
On January 14, 2025, the Internal Revenue Service (“IRS”) and the Department of Treasury issued proposed regulations under Internal Revenue Code (“Code”) section 162(m), which limits the deductibility of certain employee...more
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
On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more
The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more