On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
On December 4, 2023, the Department of Energy (DOE), Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published related proposed guidance on the eligibility of an electric vehicle for the section...more
1/10/2024
/ Automotive Industry ,
Batteries ,
China ,
Clean Car Standards ,
Clean Energy ,
Department of Energy (DOE) ,
Electric Vehicles ,
Foreign Entities ,
Infrastructure Investment and Jobs Act (IIJA) ,
Iran ,
IRS ,
Minerals ,
Motor Vehicles ,
North Korea ,
Proposed Guidance ,
Russia ,
Tax Credits ,
U.S. Treasury
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more
6/19/2023
/ Comment Period ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Manufacturers ,
Monetization ,
New Guidance ,
Registration Requirement ,
Semiconductors ,
Tax Credits ,
Technology Sector ,
Transfer of Interest ,
U.S. Treasury
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
In recent months, the IRS has continued its attack on syndicated conservation easement transactions. Many syndicated partnerships are now under IRS audit or have cases pending before the US Tax Court. Moreover, the IRS has...more
On May 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced changes in, and a new name for, a key compliance program (IR-2019-95) to identify the biggest and most...more
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of 1986, as amended...more
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities designated as “Opportunity Zones.”...more
As part of the Tax Cuts and Jobs Act of 2017 (the TCJA), Congress added new rules to the Internal Revenue Code intended to promote investments in low-income communities designated as “qualified opportunity zones.” New IRC...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 June 6, 2014, the Internal Revenue Service (IRS) released Private Letter Ruling 201423011 (the PLR), confirming that income from certain data center services can constitute “rents from real property” for purposes of the...more
On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more
On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more
On June 25, the IRS expanded its “no-rule” policy with respect to spin-offs and other tax-free corporate separations, liquidations, contributions, and reorganizations. Effective for letter ruling requests received by the IRS...more
In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final regulations under §336(e) (the Final Regulations) on May 10. Section 336(e)...more
On January 30, Treasury and the IRS issued proposed regulations relating to the proper filing of gain recognition agreements (GRAs) and other related compliance obligations (the Proposed Regulations). As a general matter, a...more