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Clawbacks U.S. Treasury

McDermott Will & Emery

US Treasury Issues Guidance on the ARPA Claw-Back Provision

McDermott Will & Emery on

Earlier this week, the US Department of the Treasury (Treasury) issued formal guidance regarding the administration of the American Rescue Plan Act of 2021 (ARPA) claw-back provision. The guidance (Interim Final Rule)...more

McDermott Will & Emery

McDermott Provides Treasury Department with Concrete Suggestions for Guidance on the American Rescue Plan Act’s Claw-Back...

McDermott Will & Emery on

The recently enacted American Rescue Plan Act of 2021 (ARPA) includes an ambiguous claw-back provision that has brought the world of state and local tax policymaking to a grinding halt. Because ARPA’s adoption occurred during...more

Eversheds Sutherland (US) LLP

Executive decision: IRS finalizes section 162(m) regulations

On December 18, 2020, the Internal Revenue Service and Treasury Department issued final regulations under section 162(m) of the Internal Revenue Code, following proposed regulations issued in December 2019. The final...more

BCLP

IRS Issues Final Regulations Quashing Taxpayer Fears of Clawback on Gifts

BCLP on

The Treasury Department issued final regulations, citing the Tax Cuts and Jobs Act (TCJA), on  November 26, 2019 (Treasury Decision 9884) confirming that taxpayers will not be subject to “clawback” of the value of their...more

Stinson LLP

IRS Eliminates Worry About "Clawback"

Stinson LLP on

In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more

Bradley Arant Boult Cummings LLP

Proposed Tax Regulations Eliminate Possibility of Clawback of Lifetime Gifts for Estate Tax Purposes

As previously posted, the Tax Cuts and Jobs Act signed into law in December 2017 (the “2017 Act”) made significant changes to the federal wealth transfer system with respect to gift and estate tax transfers during the...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Bracewell LLP

Proposed IRS Regulations Target Management Fee Waiver Arrangements

Bracewell LLP on

On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more

Goodwin

New Proposed Treasury Regulations Focus on Management Fee Waivers

Goodwin on

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

Cooley LLP

Alert: IRS Issues Long-Awaited Proposed Regulations on Management Fee Waivers

Cooley LLP on

On July 22, 2015, the Treasury Department and the IRS published proposed regulations (the "Proposed Regulations") that address the circumstances in which allocations or distributions made by a partnership to a partner that...more

Polsinelli

Proposed Regulations on Disguised Payments for Services and Management Fee Waivers

Polsinelli on

On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more

Franczek P.C.

Monthly Benefits Alert - June 2015

Franczek P.C. on

Supreme Court - As explained in more detail in separate alerts we issued over the past several days, the Supreme Court decided two major cases involving the Affordable Care Act and same-sex marriage. First, as described...more

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