The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain covered employees. The proposed regulations affect certain tax-exempt organizations, government entities, and certain entities that are treated as related to those organizations.
On November 20, 2019 Chief Judge Maurice Foley of the U.S. Tax Court delivered this year’s Fogel Lecture at Temple Law School, which he dubbed “Pathways and Pitfalls, A Candid Discussion of My Path to the Bench.” Before becoming the first African-American appointed to the United States Tax Court in 1995, Judge Foley was an attorney for the Legislation and Regulations Division of the Internal Revenue Service, Tax Counsel for the United States Senate Committee on Finance, and Deputy Tax Legislative Counsel in the U.S. Treasury’s Office of Tax Policy.
Tax relief may be coming for issuers and holders of debt instruments and parties to derivatives and other financial contracts governed by LIBOR (the London Interbank Offered Rate). The IRS published new proposed regulations on October 9 to address tax concerns as parties have begun to modify financial instruments’ reference rates in anticipation of a
This article is the first in a series of four primers on the key legal regimes incentivizing and protecting whistleblowers who report fraud: the False Claims Act (FCA) and the Securities Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), and Internal Revenue Service (IRS) whistleblower programs.