The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
8/30/2024
/ Chevron Deference ,
Corporate Counsel ,
Foreign Subsidiaries ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Tax Court ,
Tax Liability ,
U.S. Treasury
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more
5/6/2024
/ Cross-Border ,
Cross-Border Transactions ,
Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Merger Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Share Buybacks ,
U.S. Treasury
The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more
A new program offers rulings in 12 weeks, even absent a showing of business need.
Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
8/3/2023
/ Annual Filings ,
Corporate Taxes ,
Fast Track Process ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Revenue Procedures ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
In Short -
The Situation: A new nondeductible 1% excise tax imposed on certain stock repurchases (enacted as new section 4501 as part of the Inflation Reduction Act on August 12, 2022) (the "Stock Buy-back Excise Tax")...more
In Short -
The Situation: On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 into law. The Act establishes a new 15% corporate minimum tax (the "CMT") on large U.S. corporations (generally...more
In Short -
The Situation: On August 16, 2022, the Inflation Reduction Act of 2022 (the "Act") was signed into law, enacting a new nondeductible 1% excise tax on certain share repurchases (so-called "stock buybacks"). ...more
On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more
The Treasury Department and Internal Revenue Service have issued final and proposed regulations (collectively, the new regulations) under section 168(k) of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and...more
Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership.
On September...more
9/18/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Venture Capital
On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
10/11/2017
/ Alternative Minimum Tax ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Family Businesses ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
Multinationals ,
Pass-Through Entities ,
Proposed Legislation ,
Repatriation ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more
The IRS recently provided taxpayers with favorable guidance involving tax-free spin-offs. First, the IRS will resume issuing private rulings that allow a distributing corporation to satisfy debt it issued in anticipation of a...more
On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more