On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more
On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (88 FR 59576) that detail the information reporting requirements with respect to brokers of...more
Last week, the Internal Revenue Service (IRS) issued Notice 2022-37, which further extends the phase-in period for compliance with final regulations under sections 871(m), 1441, 1461, and 1473 regarding dividend...more
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
Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more
Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...more
Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material change regulations that...more
The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more
As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and measures are being considered...more
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
10/14/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Corporations ,
Foreign Entities ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Repeal ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 6, 2019, the Internal Revenue Service (Service) issued Rev. Proc. 2019-37, which grants advance consent to taxpayers seeking to change a method of accounting to comply with the new proposed regulations under...more
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more
On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. § 1.482-7A(d)(2), which provides that a...more
8/1/2018
/ Administrative Procedure Act ,
Arm's Length Principle ,
Cost-Sharing ,
Equity Compensation ,
IRS ,
Notice and Comment ,
Stock Options ,
Stock-Based Compensation ,
Subsidiaries ,
Tax Court ,
U.S. Treasury
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more