On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more
5/29/2020
/ Civil Monetary Penalty ,
Corporate Fines ,
Corporate Taxes ,
Enforcement Actions ,
IRS ,
Public Comment ,
Remediation ,
Restitution ,
Section 162(f) ,
Section 6050X ,
Settlement ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more
On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more
10/18/2019
/ Bitcoin ,
Capital Gains ,
Capital Losses ,
Charitable Donations ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Gifts ,
Information Reports ,
IRS ,
New Guidance ,
Recordkeeping Requirements ,
Revenue Rulings ,
Self-Employment Tax ,
Taxable Income ,
Virtual Currency
The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus depreciation regime may work in the context of many common acquisitions involving...more
On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in which a corporation (Distributing) obtains the requisite control of a...more
7/26/2016
/ Acquisitions ,
Board of Directors ,
Capital Structures ,
Controlled Transactions ,
IRS ,
Recapitalization ,
Safe Harbors ,
Shareholder Distributions ,
Stocks ,
Subsidiaries ,
Tax-Free Spin-Offs
On July 14, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would generally become effective for distributions under Section 355 of the Internal Revenue...more
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more
8/18/2015
/ Asset Transfer ,
Business Taxes ,
Capital Gains ,
Cost-Sharing ,
Foreign Affiliates ,
Income Taxes ,
IRS ,
Partnerships ,
Related Parties ,
Section 482 ,
Section 6662 ,
Tax Deductions ,
U.S. Treasury
On July 23, 2015, the Internal Revenue Service (IRS) and the Treasury Department proposed regulations that address the tax treatment of certain partnership interests issued in exchange for services. Of particular note, the...more