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Section 467 Leases: Maximizing Tax Benefits While Minimizing Bankruptcy Risks

As the economy continues to face challenges and the threat of bankruptcy becomes more prevalent among businesses, landlords must be more vigilant in protecting their interests in commercial leases. One area of particular...more

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

The Book Minimum Tax, Pillar 2 and Creditable Foreign Income Taxes

As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more

Inflation Reduction Act of 2022: New Corporate Book Minimum Tax and Changes for Carried Interests

On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

IRS Proposes Carried Interest Rules Recharacterizing Certain Capital Gain in Connection with Profits Interests

On July 31, 2020, the Internal Revenue Service (IRS) published proposed regulations providing guidance under Section 1061 (the “Proposed Regulations”) of the Internal Revenue Code (the “Code”). Section 1061, which was added...more

Long-Awaited Final and New Proposed Regulations Issued Under Section 163(j)

On July 28, 2020, the Internal Revenue Service and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”). These regulations...more

Temporary Regulations Provide NOL Carryback Waiver Relief to Consolidated Groups

On July 2, 2020, the U.S. Internal Revenue Service (the “IRS”) and the U.S. Treasury Department (“Treasury”) promulgated temporary regulations under section 1502 of the Internal Revenue Code of 1986, as amended (T.D. 9900)...more

7/9/2020  /  CARES Act , IRS , Treasury

IRS Issues Guidance on Interaction of Net Operating Loss and Alternative Minimum Tax Rules

On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic...more

IRS Guidance Clarifies CARES Act Relief Procedures for Partnerships

The CARES Act, enacted on March 27, 2020, provides important relief for partnerships including a correction to the bonus depreciation rules for qualified improvement property (QIP) under Section 168(e) and relief relating to...more

Opportunity Zones: Final Regulations Provide Additional Flexibility

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Opportunity Zones: Second Set of Proposed Regulations Provide Clarity

On Wednesday, April 17, 2019, the Treasury Department and the Internal Revenue Service issued a broad, investment-friendly second set of Proposed Regulations (the “Proposed Regulations”) regarding “Qualified Opportunity...more

Opportunity Zones: Government Issues Proposed Regulations

On Friday, October 19, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was...more

Opportunity Zones: Treasury and IRS Issue Proposed Regulations

The Treasury Department and the IRS issued today highly anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was introduced as part of the Tax Cuts and Jobs Act of...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

New Temporary Regulations Introduce a Welcome De Minimis Rollover-Shareholder Exception to US Anti Inversion Rules

On January 16, 2014, the Treasury Department and the Internal Revenue Service released new temporary regulations on one aspect of corporate inversions under Section 7874 (the “Regulations”) that altered and clarified the...more

Focus on Tax Controversy & Litigation - July 2013

In this issue: - District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo - IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition...more

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