On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more
4/11/2024
/ Federal Taxes ,
Income Taxes ,
Investment Tax Credits ,
IRS ,
Manufacturing Facilities ,
Partnerships ,
Registration Requirement ,
S-Corporation ,
Semiconductors ,
Tax Liability ,
U.S. Treasury
On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more
8/2/2022
/ C-Corporation ,
Carried Interest ,
Holding Periods ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Tax Cuts and Jobs Act
In recent months, the IRS has continued its attack on syndicated conservation easement transactions. Many syndicated partnerships are now under IRS audit or have cases pending before the US Tax Court. Moreover, the IRS has...more
In PLR 202020011, the Internal Revenue Service (IRS) reaffirmed that a wind energy facility owned by a utility affiliate and unrelated investor in a LLC taxable as a partnership was not “public utility property” because the...more
On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more
Chief Counsel Advice 201741018 (the CCA), which was released on October 13, 2017, considers the manner in which losses of a non-US partnership should be allocated among the partnership’s US and non-US investors in connection...more
As reported in a prior Sutherland Legal Alert, the Bipartisan Budget Act of 2015 (the 2015 Budget Act) makes significant changes to the procedural rules governing federal income tax audits and judicial proceedings that apply...more
On November 2, 2015, President Obama signed the Budget Act of 2015 (the “2015 Budget Act”), which makes significant amendments to the procedural rules governing federal income tax audits and judicial proceedings that apply to...more
On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more
3/6/2014
/ Capital Gains ,
Corporate Taxes ,
Employee Benefits ,
Energy Sector ,
Executive Compensation ,
Foreign Nationals ,
Income Taxes ,
Insurance Industry ,
Net Investment Income ,
Partnerships ,
Real Estate Market ,
REIT ,
RICs ,
S-Corporation ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Tax Returns
On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more