Tag Archives: internal revenue service

Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

Campaign for Compliance Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who make payments of certain U.S.-source income to foreign persons must comply with withholding, deposit, and reporting requirements. The IRS campaign promised to address “withholding agents who make such payments but … Continue Reading

Proposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property Interests

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of a U.S. real property interests (USRPI) by treating such gain as effectively connected with the conduct of a U.S. trade or business by such non-U.S. … Continue Reading

IRS Says Special Program Bonds Including Tribal Development Bonds May Be Current Refunded

While the advance refunding of tax-advantaged bonds remains a thing of the past, the Internal Revenue Service (IRS) issued guidance on May 22, Notice 2019-39, expanding the realm of current refundings to permit the current refunding of all existing and future tax-exempt bond programs that impose bond volume cap, issuance time deadlines, or both, for … Continue Reading

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. Shareholders

On May 23, 2019, the Internal Revenue Service (IRS) and the Treasury Department issued final regulations (the Final Section 956 Regulations) intended to mitigate the impact of Section 956 of the Internal Revenue Code (the Code) for certain domestic corporations. Consistent with the proposed regulations issued in November 2018 (see previous GT Alert here), the Final … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for June 2019 – Downward Trend Slowing Down

The Internal Revenue Service (IRS) publishes the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the AFRs and 7520 rate for the following … Continue Reading

GT Executive Summary & Detailed Analysis: IRS Issues Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations

Greenberg Traurig is pleased to provide our guidance on the Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations issued by the U.S. Treasury on April 17, 2019.     Here are the links to our two-part guidance: Part  I –  Executive Summary: IRS Issues Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for May 2019 – Downward Trend Continues

The Internal Revenue Service (IRS) publishes the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the AFRs and 7520 rate for the following … Continue Reading

Part 2: In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Proposed Reissuance Regulations

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. One was the finalization of the public notice regulations, and the second was the issuance of the proposed reissuance regulations, both of which have been long promised, and both of which were published in the Federal Register … Continue Reading

In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Final Public Notice and Approval Regulations

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. The first is the finalization of the public notice and approval regulations, commonly referred to as the TEFRA Regulations (the Final Regulations), and the second is the issuance of the proposed reissuance regulations. Both developments have been … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for January 2019 – Generally Trending Down

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month … Continue Reading

Federal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019

IRS announces the 2019 inflation-adjusted figures for gift and estate tax exemption amounts. The federal gift, estate, and GST exemption amount ( the exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift, estate, or generation-skipping transfer tax. The exemption amount is adjusted annually for inflation, … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for December 2018 – Trending Up

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month … Continue Reading

IRS Issues Proposed Section 956 Regulations Relating to Foreign Subsidiary Guarantees and Stock Pledges

The Internal Revenue Service recently issued proposed regulations under Section 956 of the Internal Revenue Code (IRC) that may allow foreign subsidiaries of U.S. multinational corporate borrowers to provide additional credit support to lenders without resulting in adverse U.S. federal income tax consequences. Although the proposed regulations may be relied upon by taxpayers for taxable … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for November 2018 – Trending Up

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following … Continue Reading

I Won the Lottery! What Do I Do Now?

Greenberg Traurig’s private client/high net worth team has the experience to advise mega-lottery winners. Our attorneys have worked with individuals who have won some of the biggest lottery awards in the United States. Our approach to advising lottery winner clients is based on three basic principles: Family privacy, security, and freedom from publicity Tax and estate … Continue Reading

Limitations for Charitable Deductions and SALT Credits

The Tax Cuts and Jobs Act (TCJA) placed a $10,000 annual limit on the deductibility of state and local taxes (SALT). In response to and attempting to work around that limitation, several states enacted programs that create charitable entities, contributions to which would entitle the donor to a credit reducing their property tax. This would … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for September 2018 – Trending Up Again

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for August 2018

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for July 2018 – Upward Trend Continues

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for June 2018 – Trending Up

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the … Continue Reading

Token Issuers and Purchasers, Beware: The IRS May Tax Each Time Tokens are Used

Many blockchain companies are using a largely unregulated means of raising funds, commonly known as an initial coin offering (ICO).[1]  An ICO consists of the issuance of a newly generated cryptocurrency (generally referred to as a token) that runs on blockchain technology, in exchange for fiat currency (such as U.S. dollars) or other cryptocurrencies like … Continue Reading

IRS Announces April 2018 Applicable Federal Rates and 7520 Rates

The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading

IRS Approves Employer Leave-Based Donation Programs to Aid Victims of the California Wildfires

In response to the devastation caused by the 2017 California wildfires, the Internal Revenue Service (IRS) approved the use of employer leave-based donation programs to provide relief to victims of the wildfires.  In Notice 2017-70, the IRS provides guidance on how employees may elect to forgo vacation, sick, or personal leave time in exchange for … Continue Reading
LexBlog