Tag Archives: IRS

The BEAT (Still) Goes On – New Final and Proposed BEAT Regulations

▪ Written by and
Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax. Clarifications about base erosion payments Clarifications about aggregate groups Election to waive deductions Read the full advisory here. [...]Read more

Federal Circuit Court of Appeals Weighs In on Willful FBAR Penalties

▪ Written by and
Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses: Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling Lower courts have split on the issue What’s next? Read the full advisory here. [...]Read more

Is the IRS “HODLing” Out on Us? IRS Issues Additional Cryptocurrency Guidance Addressing Hard Forks, Soft Forks, and Airdrops

▪ Written by , and

The IRS provided some much-needed guidance on protocol changes to blockchain. Our International Tax Group breaks it down.

  • What the forking wallet?
  • Two scenarios for hard forks
  • What about airdrops?

Read the full advisory here.

Qualified Retirement Plan Considerations and 2019 Year-End Action Items

▪ Written by
Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2019 IRS year-end amendments and offers year-end action items. Discretionary amendments Changes to hardship withdrawals Adjustment to the determination letter program Read the full advisory here. [...]Read more

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

▪ Written by and
The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code. Downward attribution beyond Subpart F, GILTI, and Section 965 Silence on the portfolio interest exemption Safe harbors and eased reporting requirements Read the full advisory here. [...]Read more

Final Hardship Distribution Rules Are Here: Does Your 401(k) or 403(b) Plan Comply?

▪ Written by
Our Employee Benefits & Executive Compensation Group examines the numerous changes – mandatory and permissible – plan sponsors can make to their 401(k) or 403(b) plans in light of new regulations for hardship distributions. When do you need to amend your plan? What are the mandatory and permissible changes? What next steps should you take? Read the full advisory here. [...]Read more

NOL Regulations Proposed

▪ Written by
Our Federal Tax Group covers the potential changes to recognizing built-in income in reaction to Treasury proposing new Section 382 regulations with a built-in feature that many will think is a bug. Using the Section 382 deduction limitation Using Section 338 for built-in gains Using the 1374 method for built-in losses Read the full advisory here. [...]Read more

Proposed Regulations Classifying Cloud Transactions and Digital Content Released

▪ Written by and
As the computer transactions of the 21st century continue to evolve, our International Tax Group downloads Treasury and the IRS’s attempt at updating the tax implications to keep up. Refreshing the 1998 regulations Classifying cloud transactions Key concerns and looking ahead Read the full advisory here. [...]Read more

Treasury’s Section 482 Regulation Losses

▪ Written by
Do what Treasury said, not what it says it meant. Earlier this month, our Federal Tax Group explains why the circuit court affirmed one Tax Court decision and reversed another in the name of consistency – and why it means regulation preambles are more important than ever. Affirming in Amazon, reversing in Altera Holding the IRS to literal terms of the regulation Similarity to the Supreme Court ruling on the census citizenship question Read the full advisory here. [...]Read more