On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships:
In new proposed regulations, the IRS identified several...more
AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more
12/22/2023
/ Acquisitions ,
Artificial Intelligence ,
CFIUS ,
China ,
Cybersecurity ,
Data Privacy ,
Energy Sector ,
EU ,
Intellectual Property Litigation ,
Intellectual Property Protection ,
International Litigation ,
Investment ,
IRS ,
Mergers ,
National Security ,
New Hires ,
New Legislation ,
New Regulations ,
Outer Space ,
Private Equity ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Taxation ,
Technology Sector ,
Trade Relations ,
Trade Restrictions ,
UK
The Inflation Reduction Act (IRA) of 2022 reflected a push by Congress and the Biden administration to address climate change by broadening the applicability of tax credits traditionally available for renewable energy to new...more
On June 21, 2023, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published proposed regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA)...more
On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the...more
On December 27, 2022, the IRS issued two notices providing key initial guidance for the new excise tax on corporate stock buybacks and the new corporate alternative minimum tax (CAMT). Both the excise tax and the CAMT were...more
12/30/2022
/ Acquisitions ,
Alternative Minimum Tax ,
Bootstrapping ,
Corporate Counsel ,
Excise Tax ,
IRS ,
Mergers ,
New Guidance ,
Section 355 ,
Share Buybacks ,
Special Purpose Acquisition Companies (SPACs) ,
Stocks
The corporate alternative minimum tax (CAMT) and the excise tax on stock repurchases, each enacted as part of the Inflation Reduction Act of 2022, will soon become effective — for the CAMT, for taxable years beginning after...more
The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more
12/14/2022
/ Acquisitions ,
Anti-Corruption ,
Antitrust Division ,
Banking Sector ,
Big Tech ,
Board of Directors ,
Bonds ,
Borrowers ,
Capital Markets ,
Capital Raising ,
China ,
Climate Change ,
Convertible Notes ,
Corporate Counsel ,
Corporate Governance ,
Corporate Restructuring ,
Creditors ,
Cross-Border ,
Cryptocurrency ,
Digital Assets ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Environmental Social & Governance (ESG) ,
EU ,
Executive Compensation ,
Financial Services Industry ,
Forum Selection ,
Investigations ,
IRS ,
Lenders ,
Mergers ,
Money Laundering ,
Partnerships ,
Publicly-Traded Companies ,
Recessions ,
Repurchases ,
Russia ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Shareholders ,
Special Purpose Acquisition Companies (SPACs) ,
Taxation ,
Technology ,
UK ,
Vertical Mergers
The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more
The Internal Revenue Service (IRS) recently released Notice 2020-41 (the Notice), providing important relief with respect to the beginning-of-construction requirement for the production tax credit (PTC) and the investment tax...more
5/29/2020
/ Begun Construction Test ,
Construction Project ,
Coronavirus/COVID-19 ,
Delays ,
Investment Tax Credits ,
IRS ,
Physical Work Test ,
Popular ,
Production Tax Credit ,
Relief Measures ,
Renewable Energy ,
Safe Harbors ,
Solar Energy ,
Wind Power
On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more
9/30/2019
/ Acquisitions ,
Built-In Gains ,
Change in Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Section 382 ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
The Internal Revenue Service (IRS) has released welcome new guidance with respect to renewable electricity production and energy investment tax credits. A notice issued on May 5, 2016, reflects changes to the production tax...more
Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more
The Internal Revenue Service (IRS) has released welcome new guidance on renewable electricity production and energy investment tax credits. A notice issued on August 8, 2014, addresses when a facility or equipment maintains...more
On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more