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U.S. Tax Court Invokes Loper Bright for the First Time

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

IRS Issues Final Prevailing Wage and Apprenticeship Regulations for Clean Energy Tax Credits

The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...more

Proposed Treasury Regulations Provide Guidance on New Clean Electricity Production and Investment Tax Credits

The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more

Final Clean Vehicle Credit Regulations Clarify Diligence and Tracing Rules

The Department of Treasury, the Internal Revenue Service, and the Department of Energy finalized guidance on the requirements for new and used clean vehicles to be eligible for federal tax credits....more

Internal Revenue Service Alters Its View on Section 355 Spin-Offs

The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Administration Finalizes Regulations on Clean Energy Tax Credit Transfers

The Department of Treasury and the Internal Revenue Service issued final regulations on requirements for taxpayers selling clean energy tax credits....more

Proposed Guidance Clarifies "Foreign Entity of Concern" Restrictions for Clean Vehicle Credit

New proposed Treasury and Department of Energy ("DOE") guidance, issued on December 1, 2023, offers clarity on which vehicles will be disqualified from the Clean Vehicle Tax Credit due to the inclusion of minerals or...more

Much-Anticipated Tax Reporting Regulations on Digital Asset Transactions Issued

Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Interim Guidance from the Treasury Department on the 1% Corporate Stock Buyback Tax

In Short - The Situation: A new nondeductible 1% excise tax imposed on certain stock repurchases (enacted as new section 4501 as part of the Inflation Reduction Act on August 12, 2022) (the "Stock Buy-back Excise Tax")...more

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

U.S. Treasury Department Releases Proposed Carried Interest Regulations

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Deductibility of Fines and Penalties: New Guidance Leaves Key Questions Unanswered

Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved. The U.S. Internal Revenue Service has released proposed regulations clarifying when fines, penalties, and...more

Favorable Net Operating Loss Utilization Rules Could be Eliminated

Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership. On September...more

Warning: U.S. Tax Regulations Impact Completed Foreign Sales Retroactively and Domestic Partnerships

The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more

Blockchain and Tax: Navigating Uncertainty

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

Proposed Regulations Address Deductibility of Business Interest Expense - Important guidance issued on the new 30 percent...

On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more

Treasury Provides Details on Transition Tax

Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

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