These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more
1/24/2025
/ Corporate Taxes ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
NPRM ,
Proposed Regulation ,
Reporting Requirements ,
Spinoffs ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Tax-Free Spin-Offs
The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more
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
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, 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 Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
11/7/2017
/ Acquisitions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Death Tax ,
EBITDA ,
Excise Tax ,
Executive Compensation ,
Foreign Corporations ,
Foreign Earned Income ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Itemized Deductions ,
MACRS ,
Mortgage Interest ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Principal Executive Officer ,
Proposed Legislation ,
REIT ,
Section 409A ,
Shareholders ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Transfer Taxes ,
Trump Administration ,
Ways and Means Committee
The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more