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Treasury Issues New Affordable Care Act Guidance

Introduction On November 24, the IRS published TD 9705, which issues final regulations relating to the requirement for an individual to maintain minimum essential health coverage under the Affordable Care Act (“ACA”). Concurrent with the issuance of the regulations, the Service issued Notice 2014-76, identifying hardship situations that exempt an individual from the individual mandate.…

IRS Releases OVDP Training Materials

The government recently released thousands of pages of training material and internal IRS guidance on the Offshore Voluntary Disclosure Program (“OVDP”). The government issued the material in response to a Freedom of Information Act request (“FOIA”) made by the Brager Tax Law Group in Los Angeles. The firm made the request as a result of…

In-Substance FATCA IGAs

Treasury previously introduced the “in-substance” intergovernmental agreements (IGA) concept when it announced on April 2, that it would treat jurisdictions that had agreed to enter into a model 1 or 2 IGA, but have not signed it, as having an IGA in effect until December 31. All jurisdictions that had an agreement in place by…

House Passes One-Year Extension for Expired Tax Breaks

The House last Wednesday passed a $41.6 billion tax extenders bill, which would extend more than 50 individual and business tax breaks for one additional year. The bill extends nearly all of the tax credits that expired at the end of 2013. The House Bill extends critical tax breaks for individuals and businesses on the…

Will Congress Pass the Marketplace Fairness Act?

In 1992, the United States Supreme Court ruled in Quill Corp. v. North Dakota that a state may only require an out of state seller to collect and remit sales tax if the seller has a physical presence in the state. To circumvent this ruling, many states have passed click-through nexus laws, which enable states…

LB&I Seeking Feedback on New IDR Procedures

Heather Maloy, Commissioner for Large Business and International, has expressed the intent of the IRS to seek feedback regarding the new information document request (IDR) procedures. The new procedures are designed to increase efficiency and develop more communication between the examiner and the taxpayer. Specifically, the procedures directs an examiner to issue a draft IDR…

EU Cracking Down on State Aid

The Treaty on the Functioning of the European Union prohibits State aid which gives an advantage to companies over their competitors unless it is justified by reason of general economic development. The EU has begun to investigate tax rulings given to companies which seem to allow those companies to understate their taxable profits. Specifically, investigations…
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aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2024 alliantNational. - All Rights Reserved.

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