Nonprofit Quick Tip: State Filings in Kentucky and Tennessee
For the first time, the IRS has issued an official form to be used for making an election under Section 83(b) of the Internal Revenue Code. Until the IRS issued Form 15620 in late 2024, taxpayers used their own “homemade”...more
In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more
Companies frequently grant incentive stock options (ISOs) or sponsor an employee stock purchase plan (ESPP) to provide tax-advantaged equity incentives to employees that are U.S. taxpayers. One aspect of the tax-advantaged...more
This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to...more
Annual Reporting on ISO/ESPP Transactions - As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require...more
As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more
In March 2024, the Internal Revenue Service (“IRS”) released a new revision to Form W-9. Forms W-9 previously provided or collected do not expire nor need to be refreshed due to the publication of the new revision....more
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more
We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more
Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more
Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more
Deadlines are approaching for employers to report employee exercises of incentive stock options and employee stock purchase plan purchases during 2022. Corporations that offer incentive stock options (ISOs) or maintain a...more
In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the context of a Liechtenstein...more
Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...more
In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more
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
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
On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more
In response to the coronavirus (COVID-19) pandemic, the Internal Revenue Service (IRS) has issued new formal guidance that extends the deadline for providers of individual retirement accounts and individual retirement...more
New formal guidance from the Internal Revenue Service (IRS) extends the deadline for providers of individual retirement accounts and individual retirement annuities (IRAs) to file Form 5498 in response to the coronavirus...more
The Internal Revenue Service (IRS), in a recently released memorandum from the Office of Chief Counsel (Chief Counsel Memorandum), has taken the position that the Employer Shared Responsibility Payment (ESRP) imposed by...more
On December 20, 2019, Congress retroactively repealed Internal Revenue Code (IRC) Section 512(a)(7), which had increased unrelated business taxable income by amounts paid or incurred for qualified transportation fringes....more
You’ve been at this Affordable Care Act reporting for years and are cruising on autopilot, right? Regardless of your confidence level, all employers need to note the extended due date for furnishing Form 1095-C to individuals...more
On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more
There are foreign national Individuals and other foreign Persons that do not have or do not qualify for a Social Security Number (SSN) but need a Taxpayer Identification Number (TIN) to file certain tax forms and schedules...more