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House Rules Committee’s revisions to One Big Beautiful Bill include amendment to partnership disguised sale rules

On May 22, 2025, the House of Representatives passed the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill,” with revisions from the House Rules Committee. On May 21, 2025, the House...more

The One Big Beautiful Bill’s impact on investments in BDCs

On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...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

Swiss sign Model 1 IGA with United States and resolve transition issues

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

Revised IRS Form W-9 impacts disregarded entities and their owners as well as US partnerships with foreign owners

The IRS recently released a revised version of Form W-9, Request for Taxpayer Identification Number and Certification, bearing a March 2024 revision date. The revised Form W-9 modifies line 3a and includes a new line 3b....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

Congress considers TCJA extenders and Taiwan tax relief

In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more

IRS Notice 2024-6 provides guidance on sustainable aviation fuel credits

The Inflation Reduction Act of 2022 established sustainable aviation fuel (SAF) tax credits to benefit United States producers and importers of certain fuel mixtures containing SAF. On December 15, 2023, the Internal Revenue...more

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Diving into the section 48 investment tax credit proposed regulations

On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy property that qualifies for the section 48...more

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