The Internal Revenue Service (“IRS”) recently released guidance relating to a new requirement for individuals to report their interests in “specified foreign financial assets.”
Ivins, Phillips & Barker has developed two tax-reduction strategies for employers that maintain VEBAs to fund retiree medical expenses for non-union employees.
In recent guidance, the Internal Revenue service appears to have changed its position on the eligibility of exchanges of certain types of intangible property for non-recognition treatment under Code section 1031. We believe this creates potential opportunities not only for structuring future exchange transactions, but also for obtaining tax-free treatment for past exchanges through an accounting method change.
It has come to our attention that some employers have been unnecessarily reducing their expense deductions for benefits paid under self-funded medical reimbursement plans based on the 2-1/2 month and 8-1/2 month payment deadlines that apply under the Code for certain other tax purposes. Any company not deducting the entire amount of their current-year liabililty for employee medical and dental expense reimbursements for this reason should consider filing an accounting method change request with the IRS.