In M&A and private equity transactions, buyers and sellers are consistently looking for ways to maximize value, which requires a critical focus on structuring the transaction in a tax-efficient manner. This pursuit of tax...more
10/11/2024
/ Acquisitions ,
Asset Purchaser ,
Business Income ,
Buyers ,
C-Corporation ,
Financial Transactions ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Mergers ,
Private Equity ,
Reorganizations ,
S-Corporation ,
Sellers ,
Shareholders
On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more
5/24/2024
/ Acquisitions ,
Excise Tax ,
Fair Market Value ,
Individual Retirement Account (IRA) ,
Initial Public Offering (IPO) ,
IRS ,
Leveraged Buyout ,
Liquidation ,
Mergers ,
Proposed Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Special Purpose Acquisition Companies (SPACs) ,
Stocks ,
U.S. Treasury
The Internal Revenue Service (IRS) recently launched a new online registration portal allowing taxpayers to begin the registration process that must be completed in order for a taxpayer to elect to transfer a credit (under...more
This past summer, the Treasury and Internal Revenue Service (IRS) published proposed Treasury Regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA) designed to enable...more
On May 31, 2023, the Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2023-44 (“Notice”) to provide additional guidance on Section 48C, a revised and expanded allocation-based...more
On November 3, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) released three Notices requesting public comments by December 3, 2022, on certain additional aspects of the clean energy tax...more
On July 27, 2022, Senator Joe Manchin and Senate Majority Leader Chuck Schumer announced that they have reached an agreement on a budget reconciliation bill (the Inflation Reduction Act of 2022, the “Act”). Although the Act...more
8/2/2022
/ Alternative Minimum Tax ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Clean Energy ,
Energy Tax Incentives ,
Foreign Corporations ,
Inflation Adjustments ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
On June 11, 2020, the U.S. Treasury Department released highly anticipated proposed Treasury Regulations on like-kind exchanges under Section 1031 (the “Proposed Regulations”). The Proposed Regulations provide much-needed...more
Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program -
On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more
11/1/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
Low Income Housing ,
New Guidance ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more
8/21/2017
/ Capital Gains ,
Exemptions ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Selling a Business ,
Tax Court