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U.S. Treasury Taxation Internal Revenue Service

Fox Rothschild LLP

IRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two Months

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On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax agency’s 162-year...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025 #2

The Senate Republicans continue to meet internally and with stakeholders regarding the provisions of a reconciliation package (H.R. 1). Senate Majority Leader John Thune (R-SD) made it clear that the Senate will make...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025

House Passes Reconciliation Package, with Senate Expected to Make Changes: On May 22, the House of Representatives passed H.R. 1, “The One, Big, Beautiful Bill Act,” legislation authorized under the FY 2025 concurrent budget...more

Seward & Kissel LLP

Should you call 911 about Section 899?

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On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

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On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Fox Rothschild LLP

Trump and Congress Nullify IRS Reporting Rule for Digital Assets

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The federal rule that would have required crypto platforms to report users’ transactions to the IRS has officially been scrapped. President Trump signed a joint congressional resolution overturning the so-called DeFi...more

Fox Rothschild LLP

President Names Yet Another Acting IRS Commissioner

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Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more

Bricker Graydon LLP

The Possible Repeal of the Tax Exemption of Municipal Bond Interest

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You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.”  This issue...more

Foodman CPAs & Advisors

FATCA Responsible Officer Certifications due 7/1/25

On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more

Cadwalader, Wickersham & Taft LLP

Final Crypto Reporting Regulations for DeFi

On December 27, 2024, the Treasury and the IRS released final regulations (the “Final Regulations”) on reporting requirements for decentralized finance (“DeFi”) participants, accompanied by a press release, and Notice 2025-3,...more

Vinson & Elkins LLP

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

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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

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations Applicable for Front-End Service Providers Facilitating Digital Asset and...

On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more

The Wagner Law Group

IRS Issues Final Regulations on Non-U.S. Tax Withholding Under Deferred Compensation Plans, IRAs and Commercial Annuities

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The Internal Revenue Service (“IRS”) and the Treasury Department on October 21, 2024, issued final regulations under Sections 3405(a) and 3405(b) of the Internal Revenue Code of 1986, as amended (“Code”). (The IRS had issued...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Fenwick & West LLP

Five Tax Cases that May Impact Your Business 2024

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The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more

Skadden, Arps, Slate, Meagher & Flom LLP

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

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Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

King & Spalding

Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors

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On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more

McDermott Will & Schulte

Key Digital Asset Tax Proposals in the Biden Administration's Green Book

On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more

Sheppard Mullin Richter & Hampton LLP

US Crypto Regulatory Enforcement Ramps Up – NFTs Now More in Focus

For the past decade the crypto space has been described as the wild west. The crypto cowboys and cowgirls have innovated and moved the industry forward, despite some regulatory uncertainty. Innovation always leads regulatory...more

Rivkin Radler LLP

Taxing NFTs as an Investment in “Art”

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Segue- Earlier this month, the Treasury released a study in which it examined how transactions in “high-value art” may facilitate the laundering of illicit proceeds.[i] The study also considered efforts that be undertaken by...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Solar Energy Facilities/Interconnection Tax: Supreme Court of Rhode Island Addresses Challenge to Imposition of Public Utility...

The Supreme Court of Rhode Island (“Court”) addressed in a June 1st opinion a challenge to the Rhode Island Public Utilities Commission’s (“PUC”) imposition of a tax as it related to companies that produce and distribute wind...more

White and Williams LLP

IRS Issues Guidance on Tax Impact of PPP Loan Forgiveness Under the CARES Act

The Internal Revenue Service (IRS) recently issued Notice 2020-32 (Notice), which discusses the deductibility of expenses that are funded by a Paycheck Protection Plan (PPP) loan and the subsequent loan forgiveness. Section...more

Seyfarth Shaw LLP

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

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Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

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