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In Rawat, DC Circuit construes the Code and regulations without deference, providing an example of statutory and regulatory...

On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

Treasury and the IRS release much-anticipated guidance, including with respect to the monetization of energy tax credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

IRS issues final (for now) debt/equity regulations

Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material change regulations that...more

No longer up in the air? Cloud transaction regulations are released

Long-awaited proposed regulations recently released by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) address the classification of certain transactions involving digital content and the...more

Proposed 163(j) regulations provide needed guidance to utilities

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more

A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

Rethinking Regulations: Treasury Report Targets Regulations to Reduce Burden

On October 2, 2017, the Treasury Department (Treasury) released a report identifying certain significant regulations for full withdrawal, partial revocation or substantial revision and noting that over 200 additional...more

10/13/2017  /  Regulatory Agenda , U.S. Treasury

Treasury Identifies Significant Regulations Subject to Modification or Repeal

On July 7, 2017, Treasury identified eight significant regulations, including regulations under sections 385 (treatment of certain debt as equity), 752 (partnership liabilities), 367 (outbound transfers of property) and 987...more

Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities 

Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more

Sweeping Changes Proposed to Tax Treatment of Related-Party Debt May Impact Private Funds

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

A New Way to Unwind (Leveraged Partnership Structures): Treasury and IRS Propose Draconian Changes to the Partnership Liability...

On January 29, Treasury and the IRS issued proposed regulations that would dramatically change the manner in which partnership liabilities are allocated among the partnership’s partners under IRC § 752 (the Proposed...more

2/5/2014  /  IRS , Partnerships , U.S. Treasury

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

New Final Regs on Use of Differential Income Stream in Evaluating Cost-Sharing Arrangements

On August 26, 2013, the United States Treasury Department issued new final regulations under Internal Revenue Code (IRC) Section 482. The new regulations provide guidance on the “income method” for determining taxable income...more

Legal Alert: New Extended FATCA Implementation Dates

On July 12, 2013, the IRS, in Notice 2013-43, and the Department of the Treasury in a Press Release of the same date, extended the implementation dates by six months for many of the withholding and account due diligence...more

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