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Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

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On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

McDermott Will & Schulte

Weekly IRS Roundup January 15 – January 19, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024. ...more

McDermott Will & Schulte

Weekly IRS Roundup November 6 – November 10, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023...more

McDermott Will & Schulte

Weekly IRS Roundup December 12 – December 16, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

McDermott Will & Schulte

Weekly IRS Roundup March 2 – 6, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 2 – 6, 2020. March 2, 2020: The US Treasury Department and the IRS released tax year 2018...more

White and Williams LLP

IRS Ends Certain State Workarounds to SALT Deduction

White and Williams LLP on

On June 11, 2019, the IRS issued final regulations that will prohibit taxpayers from using state programs to sidestep state and local tax (SALT) deduction limitations. The SALT deduction, which has been in existence for over...more

Snell & Wilmer

IRS Finalizes Regulations Simplifying 83(b) Filing Requirements

Snell & Wilmer on

On July 23rd of last year, I blogged on a set of proposed regulations eliminating the requirement that a taxpayer attach a copy of his or her Section 83(b) election to their individual tax return. This July, the IRS made the...more

Proskauer - Tax Talks

IRS Eliminates Requirement to Submit Copy of Section 83(b) Elections with Tax Return

Proskauer - Tax Talks on

The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted...more

Tucker Arensberg, P.C.

IRS Provides Guidance for Making an 83(b) Election

Tucker Arensberg, P.C. on

On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more

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