Frank Comparetto III

Eversheds Sutherland (US) LLP

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Latest Posts › Internal Revenue Code (IRC)

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IRS releases Notice 2024-60 outlining procedures for submission of greenhouse gas lifecycle analysis report in support of Section...

On July 24, 2024, the IRS issued Notice 2024-60, which sets forth the procedures for taxpayers to follow when claiming Section 45Q credits based on the “utilization” of carbon oxide. Taxpayers claiming credits based on...more

7/31/2024 / Department of Energy (DOE) , Energy Tax Incentives , Environmental Protection Agency (EPA) , Greenhouse Gas Emissions , Internal Revenue Code (IRC) , IRS , Tax Credits , Tax Reform

Treasury and the IRS address classification and ordering rules for previously taxed earnings and profits of foreign corporations

On December 14, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance (Notice 2019-01 or the Notice) describing proposed regulations that they intend to issue addressing...more

1/7/2019 / Business Profits , Corporate Taxes , Earnings Tax , Foreign Corporations , Income Taxes , Internal Revenue Code (IRC) , IRS , Proposed Regulation , U.S. Treasury

Allocation, apportionment and attribution, oh my – Proposed foreign tax credit regulations provide critical guidance

On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take...more

12/6/2018 / Controlled Foreign Corporations , Corporate Taxes , Foreign Tax Credits , GILTI tax , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Cuts and Jobs Act , U.S. Treasury

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