W. Scott Wright

Eversheds Sutherland (US) LLP

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SALT Scoreboard - Quarter 4, 2024

This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

2/17/2025 / Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , SALT , State and Local Government , Tax Credits , Tax Liability , Tax Planning , Tax Reform

IRS requests comments on the normalization requirements relating to excess tax reserves resulting from the Tax Cuts and Jobs Act

On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more

5/9/2019 / Corporate Taxes , Internal Revenue Code (IRC) , IRS , Notice and Comment , Tax Cuts and Jobs Act , Tax Rates

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

12/7/2018 / Corporate Taxes , Cost Allocation , Interest Income , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Cuts and Jobs Act , U.S. Treasury , Utilities Sector

How will Georgia conform to federal tax reform? Annual legislation introduced

The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted...more

2/5/2018 / Corporate Taxes , Internal Revenue Code (IRC) , Net Operating Losses , Repatriation , Tax Deductions , Tax Reform

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