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Department of the Treasury Invites Taxpayers to Comment on Department Regulations to Reduce Compliance Burdens

On June 14, 2017, the Department of the Treasury (the “Department”) issued a request for public comments to identify Department guidance that should be modified, eliminated, or streamlined in order to reduce compliance...more

7/3/2017  /  FinCEN , IRS , OCC , Public Comment , U.S. Treasury

The Trump Freeze Leaves New Proposed Regulations on Partnership Audit Rules out in the Cold

A White House freeze on recently issued regulations has left proposed regulations on the new Centralized Partnership Audit Regime out in the cold. On January 20, 2017, a memorandum from Assistant to the President and Chief...more

New Temporary Regulations Deny Basis Increase in Partnership Interests in Lease Passthrough ITC Structures

On July 21, the U.S. Treasury Department (“Treasury”) released temporary and proposed regulations denying a basis increase to equity holders of lessee partnerships and S corporations to account for mandatory income inclusions...more

IRS Sets Short Fuse for Comments, Guidance on New Partnership Audit Rules

As if it wasn’t going to be busy already, the Internal Revenue Service (“IRS”) has set Tax Day, April 15, 2016, as the due date for comments on significant new partnership audit rules. This new law, which was enacted as part...more

Winds of Change for Alternative Energy Tax Incentives in 2016

Congress has some unfinished business on alternative energy policy, which may provide unusual legislative opportunities in an election year. While tax credits for wind and solar power received long-term extensions in the...more

FATCA is Coming

At the end of May 2014, a bill was introduced to the Australian Federal Parliament to give effect to the United States' Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreement which was executed by...more

2014: Turbulent Waters Ahead in Tax Policy

Although the prospect for comprehensive tax reform this year is dimming, debate on tax policy issues will continue to be prominent on Capitol Hill. Between election year dynamics, changes in committee leadership, the tax...more

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more

Taxes and Politics Collide in New IRS Guidelines for 501(c)(4) Organizations: IRS Proposes to Restrict Political Activities of...

On November 29, 2013, the Internal Revenue Service (“IRS”) issued proposed rules, “Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities” (78 Fed. Reg. 71535-71542 (Nov. 29, 2013)),...more

FATCA Regulations Finally Arrive: A First Look

On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more

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