On February 21, 2025, the IRS issued Notice 2025-15, which provides guidance regarding the alternative manner of furnishing certain health insurance coverage statements to individuals under I.R.C. sections 6055(c)(3) and 6056(c)(3). President Biden signed the Paperwork Burden Reduction Act (H.R. 3797) in December 2024, eliminating the requirement to automatically furnish Forms 1095-B and 1095-C
Tax
IRS Issues Proposed Regulations to Expand Limitation on Compensation Deduction for Publicly Held Corporations
On January 16, 2025, the IRS published proposed regulations to implement and provide guidance regarding amendments made to section 162(m) as part of the American Rescue Plan Act of 2021 (ARPA). These proposed regulations expand the compensation deduction limitation for publicly held corporations under I.R.C. section 162(m), beginning in 2027.
Section 162(m) generally disallows a…
IRS Issues Ruling on Tax Treatment of Contributions and Benefits Under State Paid Family and Medical Leave Programs
The IRS issued Rev. Rul. 2025-4 on January 15, 2025, regarding the federal income and employment tax treatment and related reporting requirements of contributions to, and benefits paid under, a mandatory state paid family and medical leave (PFML) program. The ruling includes various tax treatment scenarios containing the IRS’ guidance with respect to contributions and benefits…
IRS Issues Final Regulations Governing Withholding on Certain Retirement Plan and Commercial Annuity Distributions Made to U.S. Taxpayers Abroad
On October 18, 2024, the IRS issued final regulations on withholding for qualified retirement plan payments made to United States taxpayers living outside of the country. The final regulations come five years after the IRS issued proposed regulations on the topic and almost four decades after the IRS issued Notice 87-7, the previous authority…
IRS Issues FAQs Addressing Tax Treatment of Work-Life Referral Services Provided to Employees
On April 16, 2024, the IRS issued fact sheet FS-2024-13 providing answers to frequently asked questions about the tax treatment of work-life referral services provided to employees under an employer’s work-life referral program. The FAQs clarify that, under certain circumstances, the value received from work-life referral services provided to employees through a work-life referral program…
Treasury Greenbook Includes Proposal to Alter Work Opportunity Tax Credit
On March 9, 2023, the U.S. Department of Treasury released the Greenbook (formally known as the General Explanation of the Administration’s Revenue Proposals) for FY 2024 to explain revenue proposals included in the Administration’s budget. One proposal is to increase the number of hours required to be worked by an individual for the employer to…
Administration Proposes Increased Childcare Tax Credit for Employers
As we have been discussing in recent blog posts, the Treasury Department released its Fiscal Year 2024 General Explanations of the Administration’s Revenue Proposals, commonly called the “Green Book,” on March 9, 2023. This year’s Green Book includes a proposal that both employers and employees are likely to embrace: an enhanced tax credit…
Treasury Greenbook Includes Proposal to Raise the Additional Medicare Tax Rate for High-Income Taxpayers
On March 9, 2023, the U.S. Department of the Treasury released the Greenbook (formally known as the General Explanations of the Administration’s Revenue Proposals), to explain the revenue proposals included in Administration’s budget. One proposal in the Administration’s budget would increase the additional Medicare tax rate by 1.2 percentage points for high-income taxpayers.
Self-employment earnings…
Treasury Reiterates Position on “On-Demand” Pay
Last week, the Treasury Department released the “Green Book,” formally known as the General Explanations of the Administration’s Revenue Proposals. For the second year in a row, the Green Book addresses the treatment of “on-demand” pay arrangements also known as “daily pay” or “earned wage access programs.” These arrangements permit employees to access…
IRS Repeats Cautions Regarding Aggressive Claims for Employee Retention Credit
On March 7, 2023, the IRS issued a renewed warning to employers considering an Employee Retention Credit (“ERC”) claim. While many businesses with legitimate ERC claims have already made them, a cadre of consulting firms have come forward to, in the words of the IRS, “push[] ineligible people to file” claims.…