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IRS provides additional transition relief for third party settlement organizations reporting on Form 1099-K

On November 26, 2024, the IRS issued Notice 2024-85, providing a revised timeline for the transition to the $600 threshold in section 6050W(e), as amended by the American Rescue Plan Act of 2021, for third-party settlement...more

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

Treasury and IRS release final regulations on elective payment election under CHIPS Act Section 48D

On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more

IRS Notice previews proposed regulations addressing PTEP basis of acquired CFCs

On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Treasury announces limited IRA tax guidance to ring in the new year

On December 19, 2022, Treasury announced a timeline for releasing information on certain tax provisions of the Inflation Reduction Act (IRA). As set forth in the announcement, Treasury will provide the following information...more

Tough Medicine, Part 2: Litigation lessons from Medtronic

​​​​​​​The Tax Court issued its second opinion in Medtronic following a remand by the US Court of Appeals for the Eighth Circuit (Medtronic, Inc. v. Comm’r, 900 F.3d 610 (8th Cir. 2018)) of its earlier decision. In that...more

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

Billionaires, BEAT, and Basis-Shifting: 2023 Green Book proposes tax changes affecting corporations, partnerships and individuals

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...more

Three is the magic number of new Paycheck Protection Program guidance from the IRS

The IRS recently released a trio of Revenue Procedures - 2021-48, 2021-49, and 2021-50 - related to the Paycheck Protection Program (PPP), which has been the subject of a number of our previous legal alerts. Some alerts can...more

Making a Manchin out of a molehill: Senate infrastructure and budget debates heat up

Fresh from their July 4 recess, the Senate has returned to Washington to continue infrastructure and budget bill negotiations. As previously discussed, there are two distinct legislative paths making their way through...more

Tough Medicine: Litigation lessons from Medtronic

Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more

Warren bill fundamentally changes financial account reporting requirements and substantially increases IRS funding

On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC - The Anti-Injunction Act has its limits

On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more

No harm, no foul: IRS guidance provides path to claim PPP-related deductions for taxpayers who followed its earlier - but now...

The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received Paycheck Protection Program (PPP) loans in 2020 but did not deduct all of their...more

IRS updates guidance to reflect legislation on expense deductibility under the PPP

In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of forgiven loans under the Paycheck Protection Program (PPP) are disallowed. On...more

New IRS guidance confirms PPP loans not as good or as bad as once thought

The Internal Revenue Service (IRS) recently issued a Revenue Ruling, a Revenue Procedure and a series of frequently asked questions (FAQs) posted on the IRS website addressing open questions regarding Paycheck Protection...more

Say hello to the BEAT waiver: Final regulations adopt and clarify prior proposed regulations

The ability of taxpayers to waive deductions in order to ensure that they are not subject to the base-erosion and anti-abuse tax (BEAT) was confirmed in final regulations under section 59A issued on September 1, 2020 (Final...more

High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F

Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more

IRS representatives give insight into enforcement, implementation of TCJA, CARES Act, and section 965

Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...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

Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies

The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more

COVID-19 – tax considerations for US corporate taxpayers

As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and measures are being considered...more

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