The Department of Treasury and the Internal Revenue Service released newly proposed regulations regarding the clean electricity production and investment tax credits....more
6/3/2024
/ Clean Energy ,
Energy Projects ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Oil & Gas ,
Production Tax Credit ,
Proposed Regulation ,
U.S. Treasury ,
Zero Emission Credits
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
5/6/2024
/ Cross-Border ,
Cross-Border Transactions ,
Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Merger Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Share Buybacks ,
U.S. Treasury
Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more
The U.S. Department of the Treasury has issued interim guidance outlining forthcoming proposed regulations regarding the domestic content bonus credit available to clean energy projects under the Inflation Reduction Act of...more
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
9/1/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
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
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
9/18/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Venture Capital
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
6/25/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
IRS ,
Multinationals ,
New Rules ,
Partnerships ,
Proposed Regulation ,
Retroactive Taxes ,
Stocks ,
U.S. Treasury
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
The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more
11/2/2018
/ Borrowers ,
Controlled Foreign Corporations ,
Joint and Several Liability ,
Lenders ,
Parent Corporation ,
Proposed Regulation ,
Real Estate Investments ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
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