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
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
On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...more
On October 12, 2020, the Internal Revenue Service issued Revenue Procedure 2020-44 (the Revenue Procedure) providing additional guidance related to the transition from an interbank offered rate (IBOR) to another replacement...more
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
On May 13, 2020, the Treasury Department and the Internal Revenue Service proposed revisions to the regulations under section 162(f) of the Internal Revenue Code (the “Proposed Regulations”). Generally, section 162(f) governs...more
On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more
12/11/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Final Rules ,
GILTI tax ,
International Tax Issues ,
IRS ,
Netting Agreements ,
Popular ,
Proposed Regulation ,
REIT ,
TLAC ,
U.S. Treasury
Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected -
On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more
11/5/2019
/ Acquisitions ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Debt Instruments ,
Income Taxes ,
International Tax Issues ,
IRS ,
Mergers ,
Popular ,
Preamble ,
Proposed Regulation ,
Recordkeeping Requirements ,
Required Documentation ,
Section 385 ,
Temporary Regulations ,
U.S. Treasury
On October 9, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Ruling 2019-24 (the “Revenue Ruling”) and questions and answers (the “Q&A” and, together with the Revenue Ruling, the “Guidance”) addressing certain...more
10/16/2019
/ Blockchain ,
Coinbase ,
Criminal Investigations ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Income Taxes ,
IRS ,
New Guidance ,
Reporting Requirements ,
Revenue Rulings ,
Transfer Taxes ,
Virtual Currency
On October 8, 2019, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a pre-published version of proposed regulations addressing the principal tax consequences related to the...more
10/9/2019
/ Alternative Reference Rates Committee (ARRC) ,
Benchmarks ,
Debt Instruments ,
FATCA ,
Income Taxes ,
Inter-Bank Offered Rates (IBORs) ,
International Tax Issues ,
IRS ,
Libor ,
Proposed Regulation ,
REMIC ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
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
10/3/2019
/ 1099s ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Cuts and Jobs Act
On August 28, 2019, the U.S. Department of Treasury submitted proposed regulations on the tax consequences related to the phased elimination of interbank offered rates (the “Proposed Regulations”) to the Office of Management...more
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
On August 4, 2017, the Treasury Department and the Internal Revenue Service (the “IRS”) issued Notice 2017-42 (the “New Notice”) providing taxpayers with relief from certain aspects of the final and temporary regulations...more
On July 28, 2017, the Treasury Department and the IRS announced in Notice 2017-36 (the “Notice”) that they will delay the documentation rules of Treasury regulation section 1.385-2 to debt instruments issued or deemed to be...more
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
On April 4, 2016, the Treasury Department and the IRS issued temporary regulations under Section 7874 on inversion transactions that added some new restrictions and implemented provisions previewed in two prior IRS notices...more
The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more
On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new final and proposed regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more
The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more