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White & Case LLP

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

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On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

DLA Piper

Italian Tax Authority Provides Guidance on VAT Treatment of Personnel Secondment Arrangements

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Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

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On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...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

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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

Freeman Law

Section 501(c)(3) Dissected: IRS Issues Detailed Guidance on Exempt Purposes

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On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more

Polsinelli

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

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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

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Proskauer - Not for Profit/Exempt...

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

Stinson LLP

Sales and Use Taxes: Kansas and Missouri Move to Impose Collection Obligations on Marketplace Facilitators

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Recent legislation has brought Kansas and Missouri up-to-date with the nation by instituting new tax collection requirements for out-of-state retailers lacking a physical presence in their state....more

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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Alabama: The Alabama Commissioner of Revenue has issued a series of orders. On March 18, 2020, the commissioner ordered that late payment penalties are waived for small retail businesses whose monthly retail sales during...more

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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Alabama: The Alabama Commissioner of Revenue has issued a series of orders. On March 18, 2020, the commissioner ordered that late payment penalties are waived for small retail businesses whose monthly retail sales during the...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

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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Alabama - The Alabama Commissioner of Revenue has issued a series of orders. On March 18, 2020, the commissioner ordered that late payment penalties are waived for small retail businesses whose monthly retail sales...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

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

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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

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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

McDermott Will & Schulte

Weekly IRS Roundup November 18 – 22, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

McDermott Will & Schulte

[Event] Tax in the City® A Women's Roundtable - December 5th, Chicago, IL

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We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including: • Judicial deference and potential impact on TCJA audits • Taxation of the digitalized...more

Carlton Fields

US Treasury and IRS Targets for Audit

Carlton Fields on

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

McDermott Will & Schulte

Still Tax, Even Without the Distributed Cash

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The IRS recently issued guidance on the tax treatment, withholding and reporting for required distributions from tax-qualified retirement plans. Plan sponsors should contact their retirement vendors and trustees to ensure...more

Eversheds Sutherland (US) LLP

IRS provides long-awaited cryptocurrency guidance

On October 9, 2019, the Internal Revenue Service (IRS) issued guidance addressing select issues involving the tax treatment of virtual currency transactions and reminding taxpayers of their reporting obligations. The...more

McDermott Will & Schulte

Weekly IRS Roundup September 9 – 13, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more

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