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Hardship distributions are a common distribution option that provides defined contribution (DC) retirement plan participants with a source of money in the event of a financial hardship.1 Allowing participants to [...]

On December 2, 2024, the IRS published final regulations under Code1 Sections 704 and 752 (pursuant to authority set forth in Code Section 7805(a)) relating to a partner's share of [...]

On November 19, 2024, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 761 (the Final Regulations) enabling certain entities to make [...]

Summary: As discussed in detail below, the Corporate Transparency Act (CTA) provides an exemption to its reporting requirements for certain large operating companies (the Large Operating Company Exemption or 'LOC [...]

On this episode of Just Compensation, Jessica Kriegsfeld speaks with Darren Goodman and Taryn E. Cannataro about stock options and Section 409A of the tax code, a complicated set of [...]

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28, 2024 - November 1, 2024. October 28, 2024: The [...]

On October 22, 2024, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations concerning the advanced manufacturing investment credit ('Credit') under section 48D of the Internal Revenue [...]

On October 28, 2024, the Internal Revenue Service (the 'IRS') and the Department of the Treasury ('Treasury') published final regulations (the 'final regulations') regarding the Advanced Manufacturing Production Credit under [...]

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7, 2024 - October 11, 2024. October 7, 2024: The [...]

On August 06, 2024, the Department of the Treasury and the IRS unveiled proposed regulations (REG-105128-23) addressing the dual consolidated loss (DCL) rules and their interplay with the OCED's Pillar [...]

There are several reasons why lawful permanent residents (LPRs) might choose to abandon their green cards. One common reason is relocation due to employment opportunities in another country, where a [...]

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12, 2024 - August 16, 2024. August 12, 2024: The [...]

The Internal Revenue Service (IRS) recently issued Notice 2024-55, which concerns exceptions to the 10% additional tax under section 72(t) of the Internal Revenue Code (the Code). These exceptions include [...]

Plan sponsors of Code Section 403(b) tax-sheltered annuity plans ('403(b) plans') that have not already done so may want to consider applying for an IRS determination letter or planning and [...]

Listen to this post The IRS is underway with conducting audits of 35 Section 501(c)(3) tax-exempt hospitals, with a particular focus on 'community benefit,' as the IRS announced in June [...]

Highlights The IRS on July 24, 2024, released Notice 2024-60, which provides Internal Revenue Code Section 45Q guidance for utilization of carbon dioxide and other carbon oxides. The Notice addresses [...]

I. 2023 Audit Statistics; Chances of Being Audited. The 2023 Internal Revenue Service Data Book released in April 2024 contains audit statistics for years 2013 through 2021, as of the [...]

The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them [...]

On June 17, 2024, the IRS issued Fact Sheet 2024-22, which includes nine FAQs about educational assistance programs. The Fact Sheet also links to a sample program document for employers. [...]

Introduction On June 18, 2024, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations concerning the prevailing wage and apprenticeship (PWA) requirements. These requirements have significant implications [...]

On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a [...]

The IRS recently updated its guidance for completing Form 1099-K, used primarily by 'gig' companies providing compensation using payment apps or online marketplaces and for individuals selling goods on online [...]

Each year, corporations that have employees who exercise incentive stock options (ISOs) as described under Section 422(b) of the Internal Revenue Code must file a Form 3921 with the IRS [...]

The IRS recently released Notice 2024-12, which provides some clarifications and modifications to prior IRS guidance relating to the tax treatment of specified research and experimentation (SRE) expenditures pursuant to [...]

Demonstrating that hospital finances and billing practices continue to be of interest to federal lawmakers, on August 7, a group of bipartisan senators sent letters to the Internal Revenue Service [...]

Many aspects of the US federal income taxation of cryptocurrency and non-fungible token transactions are uncertain. So much so that in June 2023, the Joint Committee of Taxation (the 'JCT') [...]

The Employee Retention Tax Credit ('ERC'), enacted as a part of the Coronavirus Aid, Relief and Economic Security Act ('CARES Act'), is a fully refundable tax credit for employers, up [...]

Partnerships are a popular business entity in the United States, particularly for small businesses. If you are considering forming a partnership, it is important to understand the fundamentals (and consequences). [...]

The IRS has made it clear publicly that it will increase efforts to identify tax fraud and underpayments by individuals and businesses with annual income of more than $400,000. But [...]

On June 14, 2023, the Department of the Treasury ('Treasury') and the Internal Revenue Service (IRS) released highly anticipated guidance relating to new Internal Revenue Code ('Code') Section 6418, which [...]

On May 31, 2023, the Department of Treasury ('Treasury') and the Internal Revenue Service ('IRS') released Notice 2023-44 ('Notice') to provide additional guidance on Section 48C,1 a revised and expanded [...]

The IRS recently published private letter ruling (PLR) 202319013 regarding the application of internal revenue code (IRC) Section 1202 to a software company. In a taxpayer favorable ruling, the IRS [...]

Seyfarth Synopsis: Just like a bad penny, schemes promising employers ways to reduce their FICA tax burden, and maybe their employees' income tax burden at the same time, keep popping [...]

The IRS has issued interim guidance to address the changes made by section 305 of SECURE 2.0 to the self-correction program under the IRS Employee Plans Compliance Resolution System (commonly [...]

Key Points Internal IRS correspondence in the form of a recent Chief Counsel Memorandum concludes that funds structured as partnerships (e.g., master funds in a standard master-feeder structure) must determine [...]

On May 2, 2023, the Department of the Treasury and Internal Revenue Service ('IRS') issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of Section 367(d)1 [...]

In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller [...]

Today we continue our series highlighting the recent publication of the Pittsburgh Tax Review edition focusing on the Restructuring & Reform Act of 1998 a quarter century after enactment. Guest [...]

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 - May 12, 2023. May 8, 2023: The [...]

This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect [...]

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The Energy Tax Team also [...]

In December 2022, the U.S. Internal Revenue Service ('IRS') issued Rev. Proc. 2022-43, which provides the final qualified intermediary ('QI') agreement.1 The prior QI agreement2 (the '2017 QI Agreement') expired [...]

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 - April 28, 2023. April 24, 2023: The [...]

On April 10, 2023, the Internal Revenue Service ('IRS') issued proposed regulations further tightening the circle around micro-captive insurance transactions.1 The release of these proposed regulations appears to have been [...]

On March 31st, the Treasury Department ('Treasury') and the Internal Revenue Service ('IRS') released proposed regulations ('Proposed Regulations') under the Clean Vehicle Credit of Internal Revenue Code Section 30D, which [...]

Summary On April 4, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released guidance on the 'energy community' tax credit adders (EC Adders) that were added [...]

Is it, or will it be age 70½, 72, 73 or 75? Let's explore these possibilities. Required minimum distributions (RMDs) from qualified retirement accounts started with the passage of The [...]

On April 4, 2023, the Department of Treasury (the 'Treasury') and the Internal Revenue Service (the 'IRS') releasedNotice 2023-29 (the 'Notice') providing a high-level overview of the rules they intend [...]

On March 31, 2023, the Department of the Treasury ('Treasury') and the Internal Revenue Service (the 'IRS') released a notice of proposed rulemaking on Section 30D of the Code1 (the [...]