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Tax Liability New Guidance Income Taxes

Cadwalader, Wickersham & Taft LLP

Partnerships Gain CAMT Alternative

On July 29, the IRS issued interim guidance intended to reduce the compliance burdens associated with applying the corporate alternative minimum tax (“CAMT”) to partnerships.  In so doing, they announced their intention to...more

McDermott Will & Schulte

IRS roundup: June 3 – 17, 2025

June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative for Missouri’s 7th congressional district from 2011 to 2023. His...more

Goodwin

UK Salaried Member Employment Tax Rules - Recent Developments

Goodwin on

This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more

DLA Piper

Chile: Servicio de Impuestos Internos publica instrucciones sobre facultad de tasación y su aplicación a reorganizaciones...

DLA Piper on

El Servicio de Impuestos Internos (SII) dictó la Circular N°23 que imparte instrucciones sobre el nuevo texto del artículo 64 del Código Tributario. A modo de contexto, el SII tiene una facultad legal para tasar el precio o...more

Buckingham, Doolittle & Burroughs, LLC

IRS Issues Guidance Simplifying Income Tax Compliance Related to the Employee Retention Credit

The IRS recently released new FAQ guidance providing a simplified procedure for addressing income tax amendments and refund claims related to Employee Retention Credit (ERC) determinations. See IRS FAQs. Taxpayers claiming...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Cadwalader, Wickersham & Taft LLP

IRS Says Crypto Protocol Changes Are Not Taxable

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Mayer Brown

US Treasury Issues Proposed Regulations on Section 30D Clean Vehicle Credit

Mayer Brown on

Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more

Polsinelli

The IRS expands crypto guidance to include “NFTs” and other “Digital Assets,” ahead of the 2022 filing season

Polsinelli on

The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more

McDermott Will & Schulte

Weekly IRS Roundup April 17 – April 23, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more

Mayer Brown Free Writings + Perspectives

US IRS Releases Final Regulations Addressing IBOR Transition

As the IBOR transition continues, business teams have frequently heard from their tax departments and advisors that amending existing contracts to add IBOR replacement mechanics or replacing an IBOR rate with a new rate can...more

Partridge Snow & Hahn LLP

Internal Revenue Service Clarifies Tax Rule for Marijuana Industry

The Internal Revenue Service (IRS) issued guidance on Thursday, September 10, 2020, to marijuana businesses. The new guidance does not change existing IRS rules, but briefly explains the rules for reporting income, paying...more

Ruder Ware

New Guidance Regarding Deferral of Withholding of Employees’ Social Security Taxes

Ruder Ware on

On August 8, 2020, President Donald Trump issued an executive order titled “Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster.” The order directed the Secretary of the Treasury to use...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Bowditch & Dewey

IRS issues guidance on Social Security tax deferral

Bowditch & Dewey on

On August 28, the IRS issued Notice 2020-65 to provide guidance on the President’s decision to allow deferral of the employee portion of Social Security taxes owing for the rest of 2020 for employees earning up to $104,000...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

Foster Garvey PC

More Good News for Oregon Taxpayers – The Oregon Department of Revenue Got It Right

Foster Garvey PC on

New guidance from the Oregon Department of Revenue (the “DOR”) with respect to Oregon’s Corporate Activity Tax (“CAT”) was issued Wednesday, May 6th. Specifically, the DOR announced that: - Certain forgivable federal...more

Foley Hoag LLP

Update: April 15th Federal Income Tax Return Filing and Payment Deadlines Postponed to July 15th

Foley Hoag LLP on

The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic. On Friday, the IRS and Treasury announced that both the...more

McDermott Will & Schulte

Weekly IRS Roundup March 16 – 20, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 16 – 20, 2020. March 17, 2020: The IRS published Rev. Rul. 2020-9 to provide various...more

McAfee & Taft

Oklahoma income tax filing dates delayed due to COVID-19

McAfee & Taft on

The day after the Oklahoma Tax Commission followed the previous guidance issued by the Internal Revenue Service to allow taxpayers to defer income tax payments but not filing requirements, U.S. Treasury Secretary Steven...more

Harris Beach Murtha PLLC

IRS Issues Formal Guidance on Postponement of 2019 Income Tax Payments and First Quarter 2020 Estimated Tax Payments

On Wednesday, March 18, the IRS issued formal guidance in the form of Notice 2020-17 (the “Notice”) that adds clarity and broadens a recent US Treasury announcement that the April 15 Federal income tax payment deadline is...more

Foster Garvey PC

The CAT Is Clearly Ruling the Roost in Oregon – It Is Occupying a Large Amount of Time for Tax Practitioners This Busy Season

Foster Garvey PC on

Temporary Rules Keep Rolling in - The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more

Jones Day

JONES DAY TALKS®: Hard Forks and Airdrops: The IRS Issues Cryptocurrency Tax Guidance

Jones Day on

The IRS's first guidance on the taxation of cryptocurrency in five years provides some new insights, but also leaves several issues unresolved. Jones Day partner Lori Hellkamp discusses Revenue Ruling 2019-24, with...more

Herbert Smith Freehills Kramer

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

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