On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more
5/29/2025
/ Budget Reconciliation ,
Business Taxes ,
Deadlines ,
Estate Tax ,
Federal Budget ,
FIRPTA ,
Gift Tax ,
GILTI tax ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Local Taxes ,
Net Investment Income ,
Proposed Legislation ,
REIT ,
SALT ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Liability ,
Tax Rates ,
Tax Reform
On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”).
The House Draft Bill is primarily...more
5/13/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Legislative Agendas ,
Proposed Legislation ,
Regulatory Agenda ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Ways and Means Committee
On January 13, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-112261-23 and REG-112261-24) adding and amending parts of the regulations...more
The U.S. Treasury Department and the Internal Revenue Service (“IRS”) published final regulations on December 4, 2024, defining “energy property” and rules applicable to energy credits (the investment tax credit, or the...more
12/16/2024
/ Electricity ,
Energy Projects ,
Energy Sector ,
Energy Storage ,
Final Rules ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Regulatory Agenda ,
Tax Credits ,
Technology Sector ,
U.S. Treasury
On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended...more
On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...more
Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more
On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code...more
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more
9/19/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Venture Capital
On November 26, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated regulations regarding the new section 163(j) limitation on business interest deductions. Section 163(j) was modified as...more
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more
On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code (the “Regulations”) that contain rules requiring...more
On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue Code that would recharacterize certain related-party debt instruments, in...more
In a positive development for employees, California recently reduced its excise tax rate for failures to comply with the California analog to Section 409A of the Internal Revenue Code of 1986, as amended (“Section 409A”)....more