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IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

Treasury and IRS Move April 15 Tax Filing Deadline Amid COVID-19 Emergency

The April 15 deadline for filing tax returns will be postponed until July 15, after comments from Treasury Secretary Steven Mnuchin and Notice 2020-18 posted March 20 by the IRS. This news follows Secretary Mnuchin’s...more

The Second Tranche of Opportunity Zone Regulations: Answers to “Substantially All” of Our Lingering Questions

On April 17, 2019, the U.S. Department of Treasury and the Internal Revenue Service released their highly anticipated second tranche of qualified opportunity zone (“OZ”) proposed regulations. This second set of proposed...more

The Recent Qualified Opportunity Zone Guidance: What We Know, What We Don’t and What It All Means

On Friday, October 19, 2018, the U.S. Treasury Department issued its first tranche of qualified opportunity zone (“OZ”) proposed regulations. Simultaneously, the IRS released Revenue Ruling 2018-29, which addresses the...more

Treasury and IRS Issue Proposed Qualified Opportunity Zone Regulations

Today, October 19, 2018, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations on the qualified opportunity zone (“OZ”) tax incentive. In addition, the IRS issued Revenue Ruling...more

Status Update on OZ Proposed Regulations

On Wednesday, October 17, 2018, the Office of Information and Regulatory Affairs of the Office of Management and Budget completed its review of the proposed qualified opportunity zone (“OZ”) regulations and sent them back to...more

Seeking Guidance? QO Zone Regulations Imminent

Today, it was announced that the proposed regulations for the qualified opportunity zone tax program (the “Program”) are being reviewed by the Office of Information and Regulatory Affairs (the “OIRA”) of the Office of...more

New Proposed Regulations Could Shake Up the Allocation of Partnership Debt

The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more

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