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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

Government Releases Final Tax Regulations on the Transition from Interbank Offered Rates

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

Proposed Treasury Regulations Clarify Requirements for Deducting Restitution and Legal Compliance Costs under Section 162(f)

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

Treasury and IRS Issue Final Regulations on Base Erosion and Anti-Abuse Tax (The BEAT)

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

Section 385 Treasury Regulations Developments

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

Treasury and the IRS Release Tax Guidance on the Transition from Interbank Offered Rates

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

Tax Guidance on the Transition From Interbank Offered Rates Under OIRA Review

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

Ninth Circuit Redo in Altera Upholds Treasury Regulation on Stock-Based Compensation

On June 7, 2019, in Altera Corp. v. Commissioner, a reconstituted panel of the U.S. Court of Appeals for the Ninth Circuit issued a new opinion upholding the validity of a Treasury Department regulation addressing the...more

Base Erosion and Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations

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

Regulations Proposed to Reduce Tax on Income Inclusions Under Section 956

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

Altera: Ninth Circuit Reverses US Tax Court and Holds that Treasury Regulation Allocating Stock-Based Compensation Expenses Is...

On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more

Treasury and IRS Issue Final Regulations on Inversions

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

Notice 2017-42 Provides for One-Year Extension of Existing Section 871(m) Rules

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

One-Year Delay to the Application of Section 385 Documentation Rules

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

Treasury and IRS Issue Regulations on Inversions and Earnings Stripping

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

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

Treasury and IRS Issue Inversion Notice

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

New Proposed Regulations Under Section 871(m) Adopt a Single Factor Test but Delay Effective Date Until 2016

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

Timeline for Initial FATCA Implementation Extended

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

7/16/2013  /  Delays , FATCA , FFI , Foreign Banks , IGAs , IRS , U.S. Treasury
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