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Treasury and IRS Propose Clean Electricity Investment Guidance

The Treasury Department and IRS on Wednesday issued an eagerly awaited notice of proposed rulemaking to incentivize clean energy facilities: the “clean electricity production credit”—Section 45Y credit—and “clean electricity...more

Treasury Announces Pass-Through Entities Will Not Be Subject to SALT Deduction Cap

In a surprising—but taxpayer-friendly—development, Treasury announced in Notice 2020-75 (available here) that it will be issuing proposed regulations that allow partnerships and S corporations to deduct certain state and...more

Treasury Issues Guidance Implementing Memorandum on Social Security Tax Deferral

Late in the afternoon on Friday, August 28, Treasury issued Notice 2020-65 providing guidance implementing President Trump’s Executive Memorandum on social security payroll tax deferral (Payroll Tax Deferral). President...more

New York State Extends Tax Filing Date in Lockstep with Federal Deadline Extension

Following U.S. Treasury Secretary Steve Mnuchin’s announcement via Twitter on Friday, March 20, that Treasury would be moving Tax Day from April 15 to July 15, New York Governor Andrew Cuomo’s Budget Director Robert Mujica...more

IRS Provides Additional Guidance Regarding Changing Tax Day to July 15

Following Treasury Secretary Steve Mnuchin’s Twitter announcement that Tax Day would be moved from April 15 to July 15, 2020, in response to the ongoing coronavirus crisis, the IRS released Notice 2020-18 (available here)...more

Partners Must Pay Self-Employment Tax on Partnership Income—Even From a 'Disregarded Entity'

The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...more

Update on Qualified Opportunity Zones: Second Set of Guidance Issued

OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

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