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New Proposed Regulations Address Spin-Off Transactions

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

Draft Guidance on the Section 45Z Clean Fuel Production Credit

The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...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

The U.S. Tax Cuts and Jobs Act: Fundamental Changes to Business Taxation

Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

Trump Administration Proposes Tax Reductions

On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more

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