On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more
5/24/2024
/ Acquisitions ,
Excise Tax ,
Fair Market Value ,
Individual Retirement Account (IRA) ,
Initial Public Offering (IPO) ,
IRS ,
Leveraged Buyout ,
Liquidation ,
Mergers ,
Proposed Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Special Purpose Acquisition Companies (SPACs) ,
Stocks ,
U.S. Treasury
The Internal Revenue Service (IRS) recently launched a new online registration portal allowing taxpayers to begin the registration process that must be completed in order for a taxpayer to elect to transfer a credit (under...more
This past summer, the Treasury and Internal Revenue Service (IRS) published proposed Treasury Regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA) designed to enable...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax related factors that need to be considered, this is often (at least in...more
On May 31, 2023, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2023-44 (“Notice”) to provide additional guidance on Section 48C, a revised and expanded allocation-based...more
On November 3, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) released three Notices requesting public comments by December 3, 2022, on certain additional aspects of the clean energy tax...more
On July 27, 2022, Senator Joe Manchin and Senate Majority Leader Chuck Schumer announced that they have reached an agreement on a budget reconciliation bill (the Inflation Reduction Act of 2022, the “Act”). Although the Act...more
8/2/2022
/ Alternative Minimum Tax ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Clean Energy ,
Energy Tax Incentives ,
Foreign Corporations ,
Inflation Adjustments ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
On June 11, 2020, the U.S. Treasury Department released highly anticipated proposed Treasury Regulations on like-kind exchanges under Section 1031 (the “Proposed Regulations”). The Proposed Regulations provide much-needed...more
Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program -
On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more
11/1/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
Low Income Housing ,
New Guidance ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more
1/15/2018
/ Acquisitions ,
Alternative Minimum Tax ,
C-Corporation ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Net Operating Losses ,
New Legislation ,
Research and Development ,
Section 162(m) ,
Tax Cuts and Jobs Act ,
Tax Deductions
Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more
11/9/2017
/ Capital Gains ,
Corporate Taxes ,
Estate Tax ,
Foreign Investment ,
Income Taxes ,
Investors ,
Joint Venture ,
Proposed Legislation ,
Real Estate Market ,
State and Local Government ,
Tax Deductions ,
Tax Reform ,
Ways and Means Committee
Letter from the Editors -
Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more
On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more
8/21/2017
/ Capital Gains ,
Exemptions ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Selling a Business ,
Tax Court