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The Tax Cuts and Jobs Act, Take Three: A Methods-Based Review of the Senate’s Initial Draft of Tax Reform Legislation

On November 2, 2017, the House Ways and Means Committee released a draft of the Tax Cuts and Jobs Act (the House proposal). On November 9, Senate Finance Committee (SFC) Chairman Orrin Hatch (R-UT) released a summary of the...more

Tax Cuts and Jobs Bill Update, November 14: Major Insurance Industry Changes

As noted in a previous Eversheds Sutherland Legal Alert, on November 2, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the House Bill). An amended version of the House Bill (the Ways and...more

The Tax Cuts and Jobs Act, Take Two: A Methods-Based Comparison of the Senate and House’s Tax Reform Plans

On November 9, 2017, the Senate Finance Committee (SFC) released a summary of its initial draft tax proposal (the Senate proposal). While the Senate proposal is similar to the House Ways and Means Committee’s proposal (the...more

Section 199 Scrutiny Continues: Chief Counsel Concludes that Merchant Discount Fees Don’t Qualify as Domestic Production Gross...

On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor

The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more

IRS Provides Safe Harbor for Inadvertent Normalization Violations

On September 7, 2017, the IRS issued Revenue Procedure 2017-47, which provides a safe harbor for regulated public utilities for inadvertent or unintentional uses of a practice or procedure that is inconsistent with the...more

IRS Releases Updated Automatic Changes in Methods of Accounting List

On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more

Think Twice: Costs Associated with Regulatory Approval for Corporate Transactions May Be Deductible

Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more

Check Your Decommissioning Costs - a Federal Court Narrows the Scope of Eligible Section 172(f) Decommissioning Costs

On March 27, 2017, the U.S. District Court for the Southern District of Florida ruled that disposal fees paid by NextEra Energy Inc. and its subsidiary, Florida Power & Light Co. (NextEra or taxpayer) into the Nuclear Waste...more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

Christmas Comes Early: IRS Provides Additional Year of Relief for Taxpayers Seeking to Implement Tangible Property Rules

On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations...more

IRS Establishes 80% Threshold for Energy Companies to Apply When Determining Whether “Substantially All” of a Major Component Has...

On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property...more

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