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U.S. Treasury Capitalization

Fenwick & West LLP

Treatment of Capitalized R&D Costs under Section 174 on a Disposition of IP: The Other Shoe to Drop

Fenwick & West LLP on

One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more

Eversheds Sutherland (US) LLP

IRS and Treasury issue final regulations on negative adjustments under UNICAP

On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Remove Obstacles to Partnership Formation, Debt Capitalization Transactions

On June 18, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) released proposed regulations that largely reinstate pre-2017 law regarding the allocation of liabilities under the partnership...more

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