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4,198 results on '"United States. Internal Revenue Service -- Powers and duties"'

1. Internal Revenue Service Internal Revenue Code Section 45Y Clean Electricity Production Credit and Section 48E Clean Electricity Investment Credit Proposed Rulemaking

Author

Zycher, Benjamin

Subjects
Government regulation, Tax credits -- Laws, regulations and rules, Air quality management -- Laws, regulations and rules, Alternative energy sources -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Inflation Reduction Act of 2022
Abstract

This comment paper discusses the fiscal implications of the rulemaking proposed by the Department of the Treasury Internal Revenue Service for implementation of the Clean Electricity Production Credit and the [...]

Published
2024

2. Advanced Notices Before IRS Contacts Third Parties in Connection with Tax Collection.

Author

Elliott, William D.

Subjects
Third parties (Law) -- Laws, regulations and rules, Tax collection -- Laws, regulations and rules, Notice (Law) -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Government regulation, Internal Revenue Code (I.R.C. 7609)
Abstract

In the last few months, there has been notable activity in the area of advanced notices that the Internal Revenue Service (IRS) is required to provide before it contacts third [...]

Published
2024

3. 2025 Planning Should Begin Before the End of 2024: The Step Transaction Doctrine Can Undermine Last-Minute Plans

Author

Shenkman, Martin M.

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax exemption -- Laws, regulations and rules, Tax planning -- Laws, regulations and rules, Government regulation, Banking, finance and accounting industries, Business
Abstract

Planning for 2025 is becoming a hotter topic as the scheduled halving of the transfer tax exemption draws closer. But while many are focusing on the end of 2025 as [...]

Published
2024

4. Navigating the Crosover in Tax Standards for Licensed Tax Practitioners in New York State: Part 1: An Examination of Tax Standards

Author

Fret, Felisha, Basile, Anthony, and Smith, Ernest Patrick

Subjects
United States. Internal Revenue Service -- Powers and duties, Accountants -- Licensing, certification and accreditation, Tax consultants -- Licensing, certification and accreditation, Tax administration and procedure -- Standards, Accounting -- Standards, Banking, finance and accounting industries, Business
Abstract

IN BRIEF CPAs are distinguished by being subject to high professional standards. But what happens when professional standards overlap, or even conflict with, federal and state laws and regulations? Under [...]

Published
2024

5. The IRS did not abuse its discretion in sustaining levy: The taxpayer did not challenge her tax liability in a CDP hearing, the Tax Court holds

Author

McKinley, John, Geiszler, Matthew, and Chasen, Isaac

Subjects
United States. Internal Revenue Service -- Powers and duties, Abuse of process -- Laws, regulations and rules, Subject matter jurisdiction -- Laws, regulations and rules, Tax appeals -- Laws, regulations and rules, Mistake (Law) -- Laws, regulations and rules, Tax penalties -- Valuation -- Laws, regulations and rules, Administrative discretion -- Laws, regulations and rules, Tax collection -- Laws, regulations and rules, Tax compromises -- Laws, regulations and rules, Due process of law -- Analysis, Notice (Law) -- Laws, regulations and rules, Government regulation, Banking, finance and accounting industries, Business, Law, Internal Revenue Code I.R.C. 6330(c)(2)(B) I.R.C. 6213(b)(1)
Abstract

The IRS did not abuse its discretion in sustaining a taxpayer's proposed levy for a tax liability the taxpayer had not properly challenged, the Tax Court held. Facts: Elizabeth White [...]

Published
2024

6. IRS steps up enforcement of the individual expatriation tax

Author

Francis, Ben

Subjects
Government regulation, Expatriation -- Taxation -- Laws, regulations and rules, Taxpayer compliance -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Heroes Earnings Assistance and Relief Tax Act of 2008
Abstract

Each year, several thousand individuals renounce their U.S. citizenship or give up their green cards, which can trigger a substantial exit tax liability. Individuals who have expatriated or are considering [...]

Published
2024

7. Change is in the sir and in your retirement plan | Viewpoint

Author

O'Toole, Martin W.

Subjects
United States. Internal Revenue Service -- Powers and duties, Retirement benefits -- Laws, regulations and rules, Spouse's share -- Laws, regulations and rules, Qualified benefit plans -- Laws, regulations and rules, Individual retirement accounts -- Laws, regulations and rules, Government regulation, Business, Business, regional, SECURE 2.0 Act of 2022, SECURE Act of 2020
Abstract

Byline: Special to the RBJ It is late September; the season is changing. Now is an appropriate time to discuss some changes to important retirement-related rules. The secure Act (2020) [...]

Published
2024

8. PRIVAT-IRS-ING.

Author

Klein, Israel

Subjects
Private sector -- Laws, regulations and rules -- Research, Tax consultants -- Management -- Laws, regulations and rules -- Research, Disclosure (Taxation) -- Laws, regulations and rules -- Research, Tax collection -- Management -- Laws, regulations and rules -- Research, United States. Internal Revenue Service -- Powers and duties, Government regulation, Company business management
Abstract

TABLE OF CONTENTS I. INTRODUCTION 89 II. TAX ADMINISTRATION IN A SELF-REPORTING SYSTEM 96 A. Multi-Phase Tax Administration 98 B. Pre-Filing Tax Education and Tax Knowledge Promotion 99 C. Assisting [...], While intended to make up for more than a decade of underfunding, the Inflation Reduction Act raises serious concerns regarding the use of nearly $80 billion in fresh funding it provides to the Internal Revenue Service (Service). In reacting to core concerns raised regarding tax administration responsibilities, this article discusses the contemporary United States tax collection system and provides analysis and policy recommendations regarding the desired distribution of tax administration responsibilities between the government and the private sector. Requiring taxpayers to self-assess and self-report casts a far-reaching regulatory burden upon the Service. To cope with its tax administration duties, private parties voluntarily partner with the Service to disseminate tax knowledge in the pre-filing phase and, through the mandatory remittance of almost 70 percent of all tax due from individuals when tax is withheld from payments made to taxpayers, contributing to the success of post-filing tax collection. Nevertheless, in the intermediate filing phase, although for-profit tax preparers are heavily engaged in assisting taxpayers to fulfill their filing obligations, because preparers are subject to contradictory incentives currently unmitigated by proper regulation, their potential for enhancing high compliance reporting by their clients is not realized. Thus, for taxpayers who use a tax preparer, this article proposes shifting the administration's responsibility for controlling filing compliance and accuracy from the Service to the private sector. That is, by introducing the notion of a paid preparer 's responsibility for their clients' compliance with tax reporting and filing accuracy. The responsibility takes the form of requiring tax preparers to substantiate their filing based on information which adds to that provided by their clients, and using external indications which assure that the reporting is accurate and compliant. Although this can be seen as a de facto transfer of a regulatory responsibility from the tax authority to the private sector (privatization), thus raising instrumental (utilitarian) and noninstrumental challenges in accordance with the existing discourse on privatization, as explained in the article, administering tax compliance by private tax preparers is not exclusive, is kept on a voluntary basis, and is not conclusive. As such, at the instrumental level, the proposed privatization constitutes a welcome, continued evolution of a self-reporting based tax administration. In addition, at the nonin-strumental level, in administering compliance through private sector tax preparers, which each taxpayer can elect to use or avoid using, the proposal strengthens the principle of taxation by consent, a core value of the United States tax system.

Published
2023

9. Didn't get a stimulus check? You might be getting $1,400 from the IRS

Author

Najmabadi, Shannon

Subjects
United States. Internal Revenue Service -- Powers and duties, Domestic economic assistance -- Planning, Company business planning, General interest, News, opinion and commentary
Abstract

Byline: Shannon Najmabadi The Internal Revenue Service said last week it will issue 'special payments' to upward of 1 million people who did not receive all of their stimulus money [...]

Published
2024

10. How One of the World's Richest Men Avoids $8 Billion in Taxes

Author

Drucker, Jesse

Subjects
United States. Internal Revenue Service -- Powers and duties, NVIDIA Corp. -- Officials and employees, Semiconductor industry -- Officials and employees, Irrevocable trusts -- Laws, regulations and rules, Chief executive officers -- Finance -- Taxation, Tax evasion -- Laws, regulations and rules, Estate tax -- Laws, regulations and rules, Semiconductor industry, Government regulation, Company financing, General interest, News, opinion and commentary
Abstract

Jensen Huang, the chief executive of Nvidia, is the 10th-richest person in the United States, worth $127 billion. In theory, when he dies, his estate should pay 40 percent of [...]

Published
2024

11. GOOD INTENTIONS: ADMINISTRATIVE FIAT AND THE GENERAL WELFARE EXCLUSION.

Author

Brunson, Samuel D. and Johnson, Christian A.

Subjects
Basis (Taxation) -- Laws, regulations and rules -- Remedies -- Research, Exceptions (Law) -- Laws, regulations and rules -- Research, Legislative power -- Laws, regulations and rules -- Research, Social security -- Laws, regulations and rules -- Research, Administrative discretion -- Laws, regulations and rules -- Research, Judicial review of administrative acts -- Laws, regulations and rules -- Research, Income tax -- Laws, regulations and rules -- Remedies -- Research, United States. Internal Revenue Service -- Powers and duties, Government regulation, United States Constitution (U.S. Const. amend. 16)
Abstract

ABSTRACT Since its introduction in 1913, the federal income tax has viewed income expansively, subjecting virtually all types of enrichment as gross income unless Congress explicitly exempted the income from [...]

Published
2023

12. The Next Wave of Partnership Litigation - APA Challenges to BBA Regulations.

Author

Meyercord, Lee and Dawson, James

Subjects
Administrative procedure -- Laws, regulations and rules, Basis (Taxation) -- Laws, regulations and rules, Limitation of actions (Taxation) -- Laws, regulations and rules, Partnership -- Taxation -- Laws, regulations and rules, Articles of partnership -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Government regulation, Bipartisan Budget Act of 2015, Administrative Procedure Act
Abstract

Taxpayers have been racking up recent wins in Administrative Procedures Act ("APA") challenges to Internal Revenue Service ("IRS") rules and regulations. (1) As a result, taxpayers and practitioners are reading [...]

Published
2023

13. Junk Money: Pitfalls and Opportunities.

Author

Whitlock, Brian T.

Subjects
Basis (Taxation) -- Laws, regulations and rules, Annuities -- Taxation -- Laws, regulations and rules, Gift tax -- Laws, regulations and rules, Generation-skipping transfer tax -- Laws, regulations and rules, Individual retirement accounts -- Taxation -- Laws, regulations and rules, Estate tax -- Laws, regulations and rules, Charitable contributions -- Laws, regulations and rules -- Taxation, Tax deductions -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Government regulation, Further Consolidated Appropriations Act for Fiscal Year 2020, Internal Revenue Code (I.R.C. 72) (I.R.C. 691(c)) (I.R.C. 1014)
Abstract

Forty years ago, in August of 1983, the State of Washington Public Power Supply System (WPPS) suffered a "Whoops" of epic proportions when they defaulted on $2.25 billion dollars of [...]

Published
2023

14. Deficiency notice invalid because IRS cannot prove last known address.

Author

Beavers, James A.

Subjects
Subject matter jurisdiction -- Laws, regulations and rules, Domicile -- Laws, regulations and rules, Tax collection -- Laws, regulations and rules, Dismissal and nonsuit -- Laws, regulations and rules, Compromise and settlement -- Taxation -- Laws, regulations and rules, Notice (Law) -- Laws, regulations and rules, Mail receiving and forwarding services -- Laws, regulations and rules, Tax liens -- Laws, regulations and rules, United States. Internal Revenue Service -- Powers and duties, Government regulation
Abstract

The Tax Court held that the IRS failed to prove that it had complied with the procedure set forth in Regs. Sec. 301.6212-2 to update the tax-payer's last known address [...]

Published
2024

15. IRS Increases 2025 401(k) Contribution Limit, Holds IRA Limit

Subjects
United States. Internal Revenue Service -- Powers and duties, Defined contribution plans -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Salary reduction savings plans -- Laws, regulations and rules, Government regulation, Business, international, Consolidated Appropriations Act of 2023
Abstract

The Internal Revenue Service (IRS) recently issued Notice 2024-80, which makes adjustments to the annual contribution limits for qualified defined contribution plans and individual retirement accounts (IRAs) for the 2025 [...]

Published
2025

16. Take The 'Hard' Out Of Hardship Distributions With A Substantiation Policy

Author

Mohs, Martha

Subjects
United States. Internal Revenue Service -- Powers and duties, United States. Congress -- Powers and duties, Tax law -- Interpretation and construction, Defined contribution plans -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Tax law, Business, international, Tax Cuts and Jobs Act of 2017, Bipartisan Budget Act of 2018
Abstract

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 [...]

Published
2024

17. The New Year Will Define Rules For Taxation Oversight And Enforcement

Author

Smeltzer, Joshua D.

Subjects
United States. Internal Revenue Service -- Powers and duties, Taxpayer compliance -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Business, international
Abstract

An old German proverb states that 'to change and to change for the better are two different things.' As 2024 ends, the legal and business communities who must navigate government [...]

Published
2024

18. 2024 Year-End Estate Planning: International Developments

Author

Rubenstein, Joshua

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax administration and procedure -- Laws, regulations and rules, Estate planning -- Laws, regulations and rules, Captive insurance companies -- Laws, regulations and rules, Government regulation, Business, international
Abstract

It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024. US tax authorities are not shaking up the international [...]

Published
2024

19. Final Regulations On Taxpayers Eligible For Direct Pay Electing Out Of Subchapter K

Author

Jewett, Michelle M.

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax elections -- Laws, regulations and rules, Partnership -- Taxation -- Laws, regulations and rules, Government regulation, Business, international, Internal Revenue Code
Abstract

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service ('IRS') issued final regulations (the 'Final Regulations') to allow certain unincorporated organizations owned by specified [...]

Published
2024

20. Updated Inflation Adjustments For Gift Tax Annual Exclusion, Unified Credit Amount, And GST Tax Exemption For 2025

Author

Cook, Maureen

Subjects
United States. Internal Revenue Service -- Powers and duties, Inflation (Finance) -- Social aspects -- United States, Gift tax -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Goods and services tax -- Laws, regulations and rules, Government regulation, Business, international, Tax Cuts and Jobs Act of 2017
Abstract

There are numerous tax exclusions and exemptions that frequently impact our clients. Each year the Internal Revenue Service (IRS) evaluates and often adjusts these exclusions and exemptions to account for [...]

Published
2024

21. Final Regulations On Partnership Recourse Liabilities Bring Clarity To Certain Tax Allocations

Author

Bartoletti, Dave J.

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax law -- Interpretation and construction, Tax administration and procedure -- Laws, regulations and rules, Liability (Law) -- Laws, regulations and rules, Partnership -- Laws, regulations and rules -- Taxation, Government regulation, Tax law, Business, international, Internal Revenue Code
Abstract

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 [...]

Published
2024

22. Index Derivatives And Current 'Basket Option' Guidance

Author

Young, Brennan W.

Subjects
United States. Securities and Exchange Commission -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Derivatives (Financial instruments) -- Laws, regulations and rules, Financial institutions -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Business, international
Abstract

Many companies are in the business of index creation and maintenance (in other words, the index sponsorship business). Several household names, such as S&P Global, Nasdaq, Bloomberg, and MSCI, each [...]

Published
2024

23. Treasury And The IRS Proposed Regulations On Previously Taxed Earnings And Profits

Author

Crouch, Larry

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Controlled foreign corporations -- Taxation, Corporate income taxes -- Laws, regulations and rules, Government regulation, Business, international
Abstract

On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of [...]

Published
2024

24. Dear Littler: What Are The Tax Implications Of Office Gift-Giving And Donation Matching?

Author

Weissman, William

Subjects
United States. Internal Revenue Service -- Powers and duties, Gift tax -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Gifts -- Laws, regulations and rules -- Taxation, Government regulation, Business, international, Internal Revenue Code
Abstract

Dear Littler, We'd like to provide gifts to our staff for the holidays but are unsure which types of gifts would trigger tax obligations for our employees. We'd also like [...]

Published
2024

25. Treasury And IRS Issue Final And Proposed Regulations Expanding Applicable Entities' Ability To Elect Direct Pay In Connection With Credit Property Owned Indirectly Through An Unincorporated Organization

Author

McGinley, Elizabeth

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax credits -- Laws, regulations and rules, Tax law -- Interpretation and construction, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Tax law, Business, international, Internal Revenue Code
Abstract

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 [...]

Published
2024

26. Biased IRS Predictive Algorithm Is Cautionary Tale For Employers

Author

Wilkinson, Christopher

Subjects
United States. Internal Revenue Service -- Powers and duties, Business enterprises -- Accounting and auditing -- Technology application, Tax auditing -- Technology application -- Demographic aspects -- Research, Algorithms -- Demographic aspects -- Research, Race discrimination -- Research, Algorithm, Technology application, Business, international
Abstract

Perkins Coie experts analyze bias-related risks of AI tools Employers should prioritize risk management, work with counsel Artificial intelligence tools have potential to lead great advances throughout society. But the [...]

Published
2024

27. Disregarded Entity Eligibility For The CTA Large Operating Company Exemption

Author

Quick, William E.

Subjects
United States. Financial Crimes Enforcement Network -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax returns -- Laws, regulations and rules, Tax law -- Interpretation and construction, Income tax -- Laws, regulations and rules, Government regulation, Tax law, Business, international, National Defense Authorization Act for Fiscal Year 2021, Internal Revenue Code
Abstract

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 [...]

Published
2024

28. Florida Hurricane Relief-IRS Offers Extended Deadlines And Tax Benefits

Author

Kramarz, Michael

Subjects
United States. Internal Revenue Service -- Powers and duties, Hurricane Milton, 2024, Tax returns -- Laws, regulations and rules, Corporations -- Taxation, Disaster relief -- Laws, regulations and rules, Government regulation, Business, international
Abstract

Florida-Based Individuals and Businesses Are Granted Extensions to File and Pay Adding to previously announced relief for taxpayers affected by Hurricanes Helene and Debby, the IRS has extended tax filing [...]

Published
2024

29. IRS Relief For Disaster Victims Now Includes Those Affected By Hurricane Milton

Subjects
United States. Federal Emergency Management Agency -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Hurricane Milton, 2024, Corporations -- Taxation, Tax administration and procedure -- Laws, regulations and rules, Disaster relief -- Laws, regulations and rules, Government regulation, Business, international
Abstract

The Internal Revenue Service (IRS) offers administrative tax relief in various forms to victims living in areas that the Federal Emergency Management Agency (FEMA) or the White House has declared [...]

Published
2024

30. IRS Extends Temporary Relief For FATCA Reporting Of US Taxpayer Identification Numbers

Author

Goldberger, Jared

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Taxpayer compliance -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Business, international, Hiring Incentives to Restore Employment Act of 2010
Abstract

The US Internal Revenue Service (IRS) released Notice 2024-78 ('Notice') in October 2024, which provides an extension of and additional temporary relief procedures for certain foreign financial institutions (FFIs) resident [...]

Published
2024

31. Treasury Finalizes New Rules For Advanced Manufacturing Production Tax Credit (Section 45X)

Author

Lang, Aaron

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Manufacturing industry -- Laws, regulations and rules -- Taxation, Tax credits -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Business, international, Inflation Reduction Act of 2022
Abstract

On October 28, 2024, the Department of the Treasury and the Internal Revenue Service (collectively 'Treasury') published new final rules for one of the Inflation Reduction Act's ('IRA') key clean [...]

Published
2024

32. Stock Options And Section 409A: What You Need To Know (Podcast)

Author

Goodman, Darren

Subjects
United States. Internal Revenue Service -- Powers and duties, Deferred compensation -- Laws, regulations and rules, Stock options -- Laws, regulations and rules, Tax law -- Interpretation and construction, Tax administration and procedure -- Laws, regulations and rules, Executives -- Compensation and benefits, Government regulation, Tax law, Business, international, Internal Revenue Code
Abstract

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 [...]

Published
2024

33. Frustrations With ERC Claims Persist, This Time With PEOs

Author

Roberts, Matthew

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax returns -- Laws, regulations and rules, Employee retention -- Laws, regulations and rules, Tax deductions -- Laws, regulations and rules, Government regulation, Business, international, Federal Unemployment Tax Act, Federal Insurance Contributions Act
Abstract

Federal payroll obligations imposed on employers can be expensive and time-consuming. Therefore, it is not uncommon for companies to outsource these responsibilities to third parties referred to as 'third-party payers' [...]

Published
2024

34. New 2025 Federal Exemption Amounts And How They Impact Estate And Gift Tax Planning

Author

Goldman, Bruce

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax exemption -- Laws, regulations and rules, Gift tax -- Laws, regulations and rules, Estate tax -- Laws, regulations and rules, Government regulation, Business, international
Abstract

New Exemption Amounts The Internal Revenue Service recently announced that the federal estate and gift tax exemption amounts will be $13.99 million per individual for gifts and deaths occurring in [...]

Published
2024

35. IRS Interim Guidance Under Secure 2.0 On 'Inadvertent Benefit Overpayments'

Author

Turner, Raymond

Subjects
United States. Internal Revenue Service -- Powers and duties, Qualified benefit plans -- Laws, regulations and rules, Government regulation, Business, international, Further Consolidated Appropriations Act for Fiscal Year 2020
Abstract

Among the provisions of SECURE 2.0 (effective December 29, 2022) welcomed by plan sponsors were the additions to the Internal Revenue Code that allow qualified plans to refrain from trying [...]

Published
2024

36. Employee Benefits-Related Limits For 2025

Author

Humes, Christopher M.

Subjects
United States. Pension Benefit Guaranty Corp. -- Powers and duties, United States. Social Security Administration -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Employee benefits -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Salary reduction savings plans -- Laws, regulations and rules, Government regulation, Employee benefits, Business, international, Emergency Economic Stabilization Act of 2008, 21st Century Cures Act of 2015, Consolidated Appropriations Act of 2016, Tax Cuts and Jobs Act of 2017, American Rescue Plan Act of 2021
Abstract

This chart shows some of the annually adjusted dollar limits that impact employee benefits, as published by the Internal Revenue Service, the Social Security Administration and the Pension Benefit Guaranty [...]

Published
2024

37. Treasury And IRS Issue Final Regulations On Section 45X

Author

Kiely, Daniel T.

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax credits -- Laws, regulations and rules, Circuit components -- Production management -- Laws, regulations and rules, Government regulation, Semiconductor device, Business, international, Internal Revenue Code
Abstract

On October 24, 2024, the US Department of Treasury ('Treasury') and the Internal Revenue Service ('IRS') released final regulations (the 'Final Regulations')1 on the Section 45X Advanced Manufacturing Production Credit [...]

Published
2024

38. IRS Issues Private Ruling That Entity With Zero Gross Income Or Assets Can Qualify As A REIT

Author

Melton, Mark A.

Subjects
United States. Internal Revenue Service -- Powers and duties, Real estate investment trusts -- Laws, regulations and rules, Income tax -- Laws, regulations and rules, Government regulation, Business, international
Abstract

Highlights The IRS recently issued a private letter ruling concluding that a real estate investment trust (REIT) having no income or assets during the year of its formation did not [...]

Published
2024

39. Retirement Plan 'Inadvertent Benefit Overpayments' Get Needed First Round Of IRS Guidance

Author

Dold, Elizabeth Thomas

Subjects
United States. Internal Revenue Service -- Powers and duties, Retirement benefits -- Laws, regulations and rules, Retirement planning -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Business, international, Internal Revenue Code
Abstract

On October 15, 2024, the IRS issued Notice 2024-77, providing interim guidance on the treatment of retirement plan 'inadvertent benefit overpayments' under Section 301 of the SECURE 2.0 Act (Pub. [...]

Published
2024

40. The IRS Issues Two Notices Regarding Preventive Care And Medical Care

Author

Amin, Katie Bjornstad

Subjects
United States. Internal Revenue Service -- Powers and duties, Medicine, Preventive -- Laws, regulations and rules, Health care industry -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Preventive health services -- Laws, regulations and rules, Health insurance -- Laws, regulations and rules, Notice (Law) -- Laws, regulations and rules, Health care industry, Government regulation, Business, international, Internal Revenue Code
Abstract

On October 17, 2024, the IRS issued two Notices: one regarding preventive care services that an HSA-compatible high deductible health plan ('HDHP') can cover on a pre-deductible basis and another [...]

Published
2024

41. Weekly IRS Roundup October 28 - November 1, 2024

Author

Spencer, Kevin

Subjects
United States. Internal Revenue Service -- Powers and duties, Powers and duties, Interpretation and construction, Laws, regulations and rules, Government regulation, Tax law, Health care costs -- Laws, regulations and rules, Tax administration -- Laws, regulations and rules, Tax law -- Interpretation and construction, Foreign corporations -- Laws, regulations and rules, Health insurance -- Laws, regulations and rules, Medical care, Cost of -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Internal Revenue Code
Abstract

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 [...]

Published
2024

42. Treasury And IRS Release Final Regulations On Advanced Manufacturing Investment Credit

Author

Staiger, Carl

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Foreign investments -- Laws, regulations and rules, Semiconductor industry -- Laws, regulations and rules, Tax law -- Interpretation and construction, Tax administration and procedure -- Laws, regulations and rules, Semiconductor industry, Government regulation, Tax law, Business, international, Internal Revenue Code
Abstract

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 [...]

Published
2024

43. IRS Ends Automatic Penalties For Late-Filed Forms 3520 And 3520-A

Author

Fink, Scott

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax returns -- Laws, regulations and rules, Government regulation, Business, international
Abstract

The Internal Revenue Service will no longer automatically impose penalties on taxpayers who file late IRS Forms 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain [...]

Published
2024

44. IRS Issues Final Rules On Intangible Property Repatriations

Author

Moore, Brian

Subjects
United States. Internal Revenue Service -- Powers and duties, Transfer pricing -- Laws, regulations and rules -- International aspects -- Accounting and auditing, Intangible property -- Intellectual property -- Taxation -- Laws, regulations and rules -- International aspects, Tax incentives -- Laws, regulations and rules, Intellectual property law, Government regulation, Business, international
Abstract

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is [...]

Published
2024

45. How To Haunt The IRS: Daugerdas v. Commissioner

Author

Alloju, Angela

Subjects
United States. Internal Revenue Service -- Powers and duties, Judicial opinions -- Cases, Restitution -- Cases, Tax assessment -- Cases, Notice (Law) -- Cases, Tax liens -- Cases, Company legal issue, Business, international
Abstract

In a bench opinion dated September 27, 2024, the Tax Court sustained a Notice of Federal Tax Lien but not the proposed levy against Daugerdas, a convicted tax shelter promoter [...]

Published
2024

46. Final Regulations Issued Regarding Section 45X Advanced Manufacturing Production Tax Credit

Author

Bresson, Michael P.

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Tax credits -- Laws, regulations and rules, Green technology, Tax law -- Interpretation and construction, Tax administration and procedure -- Laws, regulations and rules, Government regulation, Tax law, Business, international, Inflation Reduction Act of 2022, Internal Revenue Code
Abstract

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 [...]

Published
2024

47. Increase In Tax Audits Of Use Of Private Aircraft, A/k/a 'Corporate Jets'

Author

Corn, Richard M.

Subjects
United States. Internal Revenue Service -- Powers and duties, Tax returns -- Laws, regulations and rules, Tax administration and procedure -- Laws, regulations and rules, Tax auditing -- Laws, regulations and rules, Government regulation, Business, international, Tax Cuts and Jobs Act of 2017
Abstract

The IRS has announced a new audit campaign targeted at the use of private aircraft, a/k/a 'corporate jets'. This has been an intensifying area of focus by the IRS over [...]

Published
2024

48. Treasury Department Issues Final Section 48D Guidance On CHIPS Act Semiconductor Tax Incentive

Author

Elliott, Nicole

Subjects
United States. Department of the Treasury -- Powers and duties, United States. Department of Commerce -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Investment tax credit -- Laws, regulations and rules, Semiconductor industry -- Investments -- Taxation -- Laws, regulations and rules, Tax administration and procedure, Semiconductor production equipment industry -- Investments -- Taxation -- Laws, regulations and rules, Semiconductor industry, Government regulation, Semiconductor production equipment industry, Company investment, Business, international, Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022
Abstract

Highlights The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment. The Section [...]

Published
2024

49. A guide on when, where, and how to blow the whistle safely: The 'Responding to Noncompliance With Laws and Regulations' NOCLAR) interpretations included in the AICPA Code of Professional Conduct answer questions members in business may have about reporting fraud.

Author

McLamb, Chris and Havian, Eric

Subjects
American Institute of Certified Public Accountants -- Standards, Accountants -- Customer relations -- Ethical aspects -- Laws, regulations and rules, Economic incentives -- Laws, regulations and rules -- Valuation, Lex talionis -- Remedies -- Laws, regulations and rules -- Prevention, Fraud -- Remedies -- Laws, regulations and rules, Whistle blowing -- Laws, regulations and rules -- Ethical aspects -- Safety and security measures, Money laundering -- Remedies -- Laws, regulations and rules, United States. Securities and Exchange Commission -- Powers and duties, United States. Commodity Futures Trading Commission -- Powers and duties, United States. Financial Crimes Enforcement Network -- Powers and duties, United States. Internal Revenue Service -- Powers and duties, Government regulation, False Claims Act, Bank Secrecy Act of 1970
Abstract

The regulatory weaknesses that led to fraud events in the early 2000s at Enron, Halliburton, and WorldCom have in some cases been remedied. But with a new era come new [...]

Published
2023

50. Deducting travel? Keep records in order

Author

Pestronk, Mark

Subjects
United States. Internal Revenue Service -- Powers and duties, Travel agents -- Laws, regulations and rules, Tax deductions -- Laws, regulations and rules, Government regulation, Business, Travel industry
Abstract

Q:I am a self-employed travel advisor. The IRS has notified me that it has disqualified all of my personal travel deductions. The IRS auditor claimed that my business is really [...]

Published
2024

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