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Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax...

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503 (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the...more

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

U.S.-Chile Income Tax Treaty Enters Into Force

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more

Notice 2024-10 Provides Interim Guidance on the Application of the CAMT with Respect to Controlled Foreign Corporations and...

On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more

Notice 2023-80 Announces FTC and DCL Guidance For Pillar Two Taxes

On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address...more

IRS Indefinitely Extends Use of Electronic Signatures for Section 83(b) Elections

On October 17, 2023, the U.S. Internal Revenue Service (IRS) updated its Internal Revenue Manual (IRM) to fully incorporate into the IRM certain e-signature policies and procedures permitting the use of electronic signatures...more

Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure

On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...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

Inflation Reduction Act: Key Green and Blue Hydrogen and CCUS Provisions

The U.S. Congress has passed, as of today, the Inflation Reduction Act (IRA or the “Act”), which is expected to be signed into law by President Joe Biden very soon....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

IRS and Treasury Issue Final Regulations Regarding Use of Consolidated Net Operating Losses

On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code...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

Tax Planning after the GILTI and Subpart F High-Tax Exceptions

On July 23, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income (GILTI) high-tax exception (“Final...more

8/4/2020  /  CARES Act , GILTI tax , Treasury

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

Coronavirus Tax Relief Provisions Raise Surprising M&A Considerations

Two key provisions included in the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”)—the Paycheck Protection Program (PPP) and the Employee Retention Tax Credit (ERTC)—are raising surprising new issues in...more

IRS Issues Proposed Regulations On Section 45Q Carbon Oxide Sequestration Credits

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) have issued proposed regulations (REG-112339-19) providing valuable guidance on credits for the sequestration of qualified carbon oxide...more

IRS Issues Proposed Regulations For Excise Tax On Nonprofit Executive Compensation

On June 5, 2020, the U.S. Internal Revenue Service (the IRS) issued proposed regulations on Section 4960 of the Internal Revenue Code of 1986, as amended (the “Proposed Regulations”). The Proposed Regulations are “intended to...more

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

Proposed Regulations Clarify UBTI ‘Silo’ Rules, Preserve Relief For Tax-Exempt Investments in Private Equity Funds

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) issued proposed regulations (REG-106864-18) addressing the so-called “silo” rule under Section 512(a)(6) of the Internal Revenue Code,...more

IRS Announces Extension of ‘Continuity Safe Harbor’ for Renewable Energy Projects

The IRS announced in Notice 2020-41 relief for taxpayers developing renewable energy projects to satisfy the “beginning of construction” requirement by extending the four-year “continuity safe harbor” for certain projects...more

IRS Announces that Expenses Giving Rise to the Forgiveness of a Paycheck Protection Program Loan

To prevent taxpayers from claiming what the Internal Revenue Service (the IRS) believes to be an unintended double tax benefit under the Paycheck Protection Program (PPP), the IRS issued Notice 2020-32, 2020-21 I.R.B. 1 (the...more

Stimulus Package Lacks Relief For Renewable Energy

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted as early as March 27, 2020. The CARES Act provisions are intended to provide individuals and companies with liquidity as the world...more

Tax Relief Provisions in the CARES Act Stimulus Package

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted, as early as March 27, 2020. The CARES Act contains tax provisions intended to provide individuals and companies with liquidity as...more

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