Fox Rothschild LLP

The Treasury Department and the IRS released their 2017-2018 Priority Guidance Plan, which prioritizes various tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other
Continue Reading IRS’S 2017-2018 Priority Guidance Plan Reflects Executive Orders On Regulations

The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident
Continue Reading Three More Countries Will Now Provide IRS Information on Bank Interest paid to Nonresident Aliens

On November 1, 2016, the IRS issued Notice 2016-66 imposing new reporting requirements on micro-captives and their material advisors (see prior post describing the Notice). On March 27, 2017,
Continue Reading Court Denies Motion for Preliminary Injunction Prohibiting the IRS from Enforcing the Micro-Captive Disclosure Requirements in Notice 2016-66

On January 20, 2017, the White House issued a Memorandum freezing all new regulations (former President Obama issued a similar freeze at the start of his administration).  In addition, on
Continue Reading Regulatory Freeze on Tax Guidance Begins to Thaw While Scope of Regulatory Reduction Order Still Unclear

Previously, we discussed Congress’s enactment of the FAST Act requiring the IRS to use private debt collection agencies to recover inactive tax receivables. In September, the IRS announced that it
Continue Reading IRS Provides Sample Letter Informing Taxpayers that Their Account was Referred to a Private Collection Agency