On May 28, 2020, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under Section 45Q of the Internal Revenue Code (Section 45Q) for the capture, utilization...more
6/16/2020
/ Audits ,
Carbon Capture and Sequestration ,
Compliance ,
Environmental Protection Agency (EPA) ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Proposed Regulation ,
Tax Credits ,
U.S. Treasury
On May 28, 2020, the Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which provides a credit for the capture...more
On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more
On May 7, 2020, in response to a letter from a consortium of U.S. Senators dated April 23, 2020 (the Senate Letter), the Treasury Department stated that it intends to modify rules related to the Continuity Safe Harbor (as...more
On April 10, 2020, the IRS and Treasury Department released Revenue Procedure 2020-22 (the Revenue Procedure), providing guidance with respect to the application of the provisions of the Coronavirus Aid, Relief, and Economic...more
Last week, in a pair of notices released under President Trump’s March 13, 2020 Emergency Declaration relating to the coronavirus pandemic, the IRS and the Treasury Department offered relief for tax return filing and tax...more
3/24/2020
/ Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more
The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more
1/14/2020
/ C-Corporation ,
Choice of Entity ,
Corporate Taxes ,
Energy Sector ,
Energy Storage ,
IRS ,
K-1 ,
Master Limited Partnerships ,
Midstream Contracts ,
Offshore Drilling ,
Oil & Gas ,
Operating Leases ,
Pipelines ,
REIT ,
Tax Deductions ,
UBTI
In connection with the purchase and sale of the stock of a target corporation (a Corporate Target), the target often incurs various transaction costs (Transaction Costs) that may yield significant tax deductions (Transaction...more
6/28/2019
/ Acquisitions ,
Business Valuations ,
Complex Corporate Transactions ,
Corporate Taxes ,
Net Operating Losses ,
Purchase Agreement ,
Stock Sale Agreements ,
Target Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Transaction Costs
Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity,...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
2/6/2019
/ Corporate Taxes ,
Income Taxes ,
IRS ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Private Letter Rulings ,
Push-Out Requirements ,
Tax Audits ,
Tax-Free Spin-Offs ,
U.S. Treasury ,
Venture Capital
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
11/7/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Energy Projects ,
Investment Tax Credits ,
Investors ,
IRS ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
U.S. Treasury
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
10/18/2018
/ Business Taxes ,
Construction Industry ,
Energy Projects ,
Interim Rule ,
Investment Tax Credits ,
Investors ,
IRS ,
NAICS ,
Partnerships ,
Physical Work Test ,
Proposed Regulation ,
Protecting Americans from Tax Hikes (PATH) Act ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Reform ,
UBTI
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
9/20/2018
/ Anti-Avoidance ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Publicly-Traded Companies ,
REIT ,
SALT ,
Section 199 ,
Tax Cuts and Jobs Act ,
W-2
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
9/12/2018
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Energy Sector ,
International Tax Issues ,
IRS ,
MACRS ,
Property Tax ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
9/4/2018
/ Acquisitions ,
Arms Length Transactions ,
Bonus Depreciation ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
MACRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
8/31/2018
/ Acquisitions ,
Bonus Depreciation ,
Construction Industry ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
MACRS ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more
5/16/2018
/ Audits ,
Bipartisan Budget Act ,
Business Taxes ,
C-Corporation ,
IRS ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
S-Corporation ,
Special Education ,
TEFRA ,
U.S. Treasury ,
Underpayment
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
5/3/2018
/ Audits ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Private Equity Funds ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
TEFRA
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
4/17/2018
/ Bi-Partison Balanced Budget Act (BBA) ,
Corporate Taxes ,
Energy Sector ,
FCC ,
FIRPTA ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
IRS ,
Like Kind Exchanges ,
Loss-Carryover ,
Net Operating Losses ,
New Rules ,
Opt-Outs ,
Partnership Agreements ,
Partnerships ,
Push-Out Requirements ,
Tax Audits ,
Tax Cuts and Jobs Act
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
4/6/2018
/ Base Erosion Tax ,
C-Corporation ,
Corporate Taxes ,
Entertainment Industry ,
Foreign Affiliates ,
GILTI tax ,
Income Taxes ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
Renewable Energy ,
Tax Audits ,
Tax Deductions ,
Tax Liability
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/16/2018
/ Base Erosion Tax ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Energy Sector ,
GILTI tax ,
Holding Periods ,
International Tax Issues ,
Pass-Through Entities ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/1/2018
/ Audits ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
FIRPTA ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
TEFRA ,
Underpayment
The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more
2/16/2018
/ Base Erosion Tax ,
Corporate Taxes ,
Energy Sector ,
Holding Periods ,
International Tax Issues ,
IRS ,
Partnerships ,
REIT ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more
8/8/2017
/ Business Taxes ,
FIRPTA ,
Foreign Partner ,
Income Taxes ,
International Tax Issues ,
IRS ,
Non-US Entities ,
Partnership Interests ,
Partnerships ,
Tax Court ,
Tax Liability