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Energy tax credit transfers: Treasury and IRS issue final regulations on the section 6418 transferability rules

[unable to retrieve full-text content]On April 25, 2024, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations on the transferability of certain tax credits under the...more

Second time’s the charm? New proposed section 163(j) regulations treat electing CFC groups as a single corporation and eliminate...

Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include: ..An election under which a controlled foreign corporation (CFC)...more

Relief for REMICs addressing phaseout of LIBOR

New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, 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

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

New Temporary and Proposed Regulations Offer Welcome Clarification on Application of the Embedded Loan Rule

On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to...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

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