Tax Law

Recent Posts

IRS Voluntary Disclosure Program Gets High Marks From Practitioners, So Far
Posted on 3 Sep 2009 by Tax Analysts Editorial Staff

As hundreds if not thousands of individuals rush to come clean about their undisclosed offshore accounts, Tax Analysts spoke with several practitioners to get their impression of the voluntary disclosure program and the reduced penalty regime. Their verdict... Read More

Pepper Hamilton, LLP: Employers May Be Responsible for Tax Consequences of a Lump-Sum Back Pay Award
Posted on 19 Feb 2009 by Michael J. Canavan

The U.S. Court of Appeals for the Third Circuit recently ruled that workers who receive a lump-sum back pay award after proving they have been discriminated against may have that award “grossed up” to offset its tax consequences. The Third... Read More

Tax Reform Task Force Hears Argument for ReadyReturn
Posted on 22 Oct 2009 by Tax Analysts Editorial Staff

President Obama's tax reform task force on October 16 heard from a proponent of creating IRS-prepared tentative tax returns, an idea that some say could inexpensively make a significant dent in the tax gap. Stanford Law School Prof. Joseph Bankman... Read More

IRS Announces Game-Changer: Announcement 2010-9 Proposes to Modify IRS Policy of Restraint
Posted on 28 Jan 2010 by Robin Greenhouse, Michael Kelleher, Jean Pawlow

The IRS proposes to require business taxpayers to disclose their “uncertain tax positions” on a new schedule to be attached to their federal tax returns. Perhaps in anticipation of the Supreme Court of the United States granting Textron’s... Read More

Volunteer Tax Attorneys Making a Difference in the Lives of Low Income Taxpayers
Posted on 18 Nov 2009 by Volunteer Legal Services Program

Attorneys and other tax professionals across the nation can explore Low Income Taxpayer Clinic pro bono opportunities at the IRS.gov site page here . ... Krista Denton is Director of the Low Income Taxpayer Clinic (LITC) , established by the Volunteer... Read More

IRS Allows Safe Harbor 401(k) Plans to Suspend Nonelective Contributions
Posted on 11 Jun 2009 by George W. Braun and Joseph F. Murphy

On May 18, 2009, the Internal Revenue Service issued proposed regulations allowing safe harbor 401(k) plan sponsors that experience a “substantial business hardship” to suspend or reduce safe harbor nonelective contributions during a plan... Read More

New Law Allows a 2009 Deduction for 2010 Charitable Contributions for Haiti Disaster Relief
Posted on 27 Jan 2010 by Mark A. Muntean

On January 22, 2010, President Obama signed into law HR 4462 accelerating the deduction for certain charitable contributions made in cash to benefit the victims affected by the earthquake in Haiti on January 12, 2010. For charitable contributions made... Read More

Pepper Hamilton, LLP: Have You Provided Required Tax Statements for 2008 ISO Exercises?
Posted on 22 Jan 2009 by David Kaplan and Karen Gelula

Section 6039(a)(1) of the Internal Revenue Code (the Code) requires corporations to provide written statements to optionees who exercise incentive stock options (ISOs). The statements must contain specified information regarding the shares acquired and... Read More

Key Energy-Related Tax Provisions in the 2011 Budget Proposal
Posted on 10 Feb 2010 by Pugh, Tingle, Chiampou, Hong Ngo

President Obama's budget proposal reveals the administration's agenda and priorities with respect to energy tax issues. On February 1, 2010, the Obama administration introduced its 2011 budget proposal (Proposal), which called for approximately... Read More

Sutherland Legal Alert: Bringing Certainty to an Uncertain Tax Position: IRS LB&I Directive Addresses Partial Worthlessness Deductions Claimed by Insurance Companies
Posted on 19 Sep 2012 by Sutherland Asbill & Brennan LLP

By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions... Read More

Caplin & Drysdale Alert: The Gift Tax and Contributions to Section 501(c)(4) Organizations
Posted on 14 Jul 2011 by Caplin and Drysdale

July 11, 2011 On July 7, 2011, the IRS announced the suspension of enforcement activity focused on the gift tax implications of gifts to section 501(c)(4) organizations. The July 7 announcement comes in the wake of disclosure of five audits in progress... Read More

News Analysis: How the U.S. Is a Tax Haven for Mexico's Wealthy
Posted on 26 Aug 2009 by Tax Analysts Editorial Staff

As if Treasury Secretary Timothy Geithner didn't have enough on his plate, there's one underappreciated problem his department now must address. This latest headache can be summarized in three words: U.S. bank secrecy. The issue landed on Geithner's... Read More

Sustainability, CleanTech and Climate Change Alert
Posted on 14 Jul 2009 by Todd Reinstein

On July 9, the Treasury released terms and conditions of the highly anticipated "1603 Program," which provides cash grants in lieu of tax credits for renewable energy property. The Treasury is not yet accepting applications, but to expedite... Read More

Taxes and Income Inequality
Posted on 2 Sep 2009 by Tax Analysts Editorial Staff

Households making $1 million or more account for just 1 in 364 taxpayers, yet they captured an astonishing 36.1 percent of the total real increase in incomes in America from 2006 to 2007, according to my analysis of new data. Even among the rich, most... Read More

IRS Announces Employee Benefit Plan Limits for 2013
Posted on 25 Oct 2012 by McDermott Will & Emery

By Jeffrey M. Holdvogt , Diane M. Morgenthaler and Adrienne Walker Porter The Internal Revenue Service recently announced cost-of-living adjustments (COLA) to the applicable dollar limits on various employer-sponsored retirement and welfare plans for... Read More