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Tax Law (and Controversy) Under the Trump Administration

As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more

CAMT Claus Is Staying In Town?

Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice. However, taxpayers and their advisors wishing for a repeal of the corporate alternative minimum tax in 2025...more

CAMT Touch This: Treatment of Tax Credits, Direct Pay, and Transferability under the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

CAMT and Partnerships: A Taxing Relationship Explained

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate...more

CAMT Count Me Twice: Determining CAMT AFSI in Mergers and Acquisitions

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Why CAMT I Get Away From You: Losing Applicable Corporation Status Under the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

The Heat Is on for Large Partnership Audits

Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more

IRS Internal Memorandum Questions NIL Collectives’ 501(c)(3) Tax-Exempt Status

The IRS recently issued an internal memorandum to the effect that many Name-Image-Likeness (NIL) collectives will not qualify for 501(c)(3) tax-exempt status, including those that had previously obtained tax exemption letters...more

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

[Webinar] Tax in the COVID-19 Era: CARES Act Tax Relief and IRS Guidance - May 6th, 12:00 pm - 1:15 pm CT

CARES Act tax relief is designed to put cash in the pockets of taxpayers in distress. In this presentation, a panel of V&E’s tax and executive compensation lawyers will discuss how to maximize the benefit of these provisions,...more

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