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On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more
The IRS recently released proposed regulations interpreting the provisions of the Code pertaining to donor-advised funds ("DAFs"). The regulations provide needed definitions of working terms such as DAFs, Donors and...more
Seyfarth Synopsis: As previously reported here, on December 20, 2023, the IRS issued Notice 2024-2 (the “Notice”) providing guidance on several outstanding questions related to provisions under SECURE 2.0. This blog post...more
Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more
In real life (and especially, it seems, in tax law) it is more like to be the lack of a timely piece of paper that causes the taxpayer to lose. In the course of administering a trust, it sometimes happens that mistakes...more
IRS Notice 2020-68 (Notice) provides the first round of guidance on a number of provisions under the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the Bipartisan American Miners Act of...more
On December 20th, before the outbreak of COVID-19 and the resulting pandemic, President Trump signed into law the Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more
This article focuses on 401(k) and 403(b) plans that are in one of the following situations: 1. The plan failed ADP or ACP testing and must distribute excess amounts to its higher-ranking employees or make additional...more
On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more
Seyfarth Synopsis: The IRS recently issued somewhat helpful guidance to plan administrators on what to do about the constant problem of uncashed benefit checks from qualified retirement plans. The initial excitement upon...more
On August 14, 2019, the IRS issued Revenue Ruling 2019-19, providing guidance to both tax-qualified plan administrators and participants on the tax treatment of plan distribution checks that are not cashed. ...more
Participants and beneficiaries are sometimes slow to cash qualified retirement plan distribution checks, especially when the checks are relatively small. This may result in the check being cashed in a year after the year the...more
Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth....more
The oldest of the 75 million baby boomers have begun turning 70 in 2016. Becoming a septuagenarian is a milestone in itself, but it also means that soon the IRS will likely be expecting you to start cashing out your...more