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Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors

On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more

IRS and Treasury Issue Interim Guidance on 1% Stock Buyback Tax

On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more

IRS Provides Temporary Guidance on the Treatment of Certain Stock Distributions by Publicly Offered REITs and RICs

On May 4, 2020, the Internal Revenue Service (the “IRS”) released temporary guidance (Revenue Procedure 2020-19, or “the Revenue Procedure”) on the treatment of certain stock distributions by publicly offered real estate...more

Anticipated IRS Guidance on Section 45Q Rumored to Be Just Around the Corner

Investors and project sponsors await proposed regulations and interim guidance under Section 45Q of the Internal Revenue Code to resolve uncertainty and unlock significant carbon capture, utilization and storage market...more

IRS and Treasury Release Final Opportunity Zone Regulations

On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Foreign Guarantees and Collateral in Play Following Finalization of Deemed Dividend Regulations

On May 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more

IRS and Treasury Release Second Round of Qualified Opportunity Zone Guidance

On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more

IRS Issues Proposed Regulations Limiting the Impact of Deemed Dividend Rules Under Section 956

On October 31, 2018, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) which likely will facilitate (i) the making of loans by foreign corporate subsidiaries to a U.S. parent...more

IRS and Treasury Issue Long-Awaited Proposed Guidance on Qualified Opportunity Fund Rules

On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more

IRS Issues Guidance on Treatment of Certain Foreign Income Inclusions for REIT Income Test Purposes

On September 13, 2018, the Internal Revenue Service (the “Service”) released Revenue Procedure 2018-48 (the “Revenue Procedure”), which provides guidance on how certain items of foreign-related income are treated for purposes...more

IRS Provides Safe Harbor Valuation Methods for Tax-Free Reorganizations

On January 23, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2018-12 (the “Revenue Procedure”) detailing a safe harbor that will permit taxpayers to utilize average-price methods for purposes of...more

Energy Newsletter - September 2017

Managing Decommissioning Risks in Asian M&A Transactions - By the end of 2026, approximately 134 producing Concessions and Production Sharing Contracts (each, a “PSC”) will have expired in South Asia. It is expected that 900...more

IRS Rejects Investors' Claim for Refined Coal Credits in Technical Advice

In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more

Tax Court Overrides Key Revenue Ruling on the Tax Treatment of the Sale of U.S. Partnership Interest by Foreign Persons

In a July 13, 2017 opinion, the United States Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner refused to follow the long-held IRS position found in Revenue Ruling 91-32 (“the “Revenue...more

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

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