On April 30, 2024, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Final Treasury Regulations (T.D. 9993) (the “Final Regulations”) providing guidance relating to the election...more
On March 22, 2024, the IRS issued additional guidance (Notice 2024-30) on the energy communities provision of the Inflation Reduction Act. This latest guidance is narrowly focused on two topics: (1) expanding the “hook” by...more
On March 5, 2024, the Internal Revenue Service and the Treasury Department issued final Treasury Regulations (the “Final Regulations”) updating and finalizing previously published proposed Treasury Regulations relating to the...more
On November 22, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing long-awaited guidance and...more
On November 17, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing guidance and amending...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) are steadily churning out guidance on the implementation of the Inflation Reduction Act’s (the “IRA”) expanded tax credits for renewable and...more
On April 27, 2021, the U.S. Tax Court issued its decision in Mylan, Inc. v. Comm’r of Internal Revenue regarding which legal fees that a generic-drug manufacturer incurs in connection with its Abbreviated New Drug Application...more
On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) was signed into law on March 27, 2020. Section 2307 of the CARES Act provides a technical correction to Public Law 115-97, commonly referred to as the...more
On September 9, 2019, the U.S. Department of the Treasury issued proposed regulations that would limit the ability of certain corporations to utilize prior year losses, potentially increasing the tax burden of such...more
New partnership audit rules enacted into law on November 2, 2015 (the “New Partnership Audit Rules”) generally call for all determinations of adjustments to income and payments of tax pursuant to a partnership tax audit,...more