On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more
Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes -
On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more
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
9/12/2023
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On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more
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
On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the “transition tax”). Section 965...more