Tax Law News and Insights

Treasury and the IRS have finalized a new "disregarded payment loss" (DPL) regime that can require domestic corporations to include in income amounts with respect to payments that are disregarded for US tax purposes but that are deductible under foreign tax law. Proposed regulations addressing DPLs, as well as aspects...

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Last month, the Department of the Treasury and the Internal Revenue Service ("IRS") issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in Treasury Department Circular 230 ("Circular 230") and apply to attorneys, certified public accountants, and enrolled agents who...

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The IRS has made it clear that it is doubling down on efforts to pursue individuals who fail to file tax returns, particularly high-income earners. This announcement comes as part of a broader strategy to increase compliance and close the tax gap, aligning with previous warnings about an uptick in...

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