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
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
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
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
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
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
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
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 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
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
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 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
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
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
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
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
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
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more
On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...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 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 September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more
9/19/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Venture Capital
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