On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more
On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more
On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more
4/18/2024
/ Acquisitions ,
Capital Markets ,
Corporate Governance ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
International Tax Issues ,
IRS ,
Mergers ,
Private Equity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Share Buybacks ,
Stock Repurchases ,
Tax Liability ,
U.S. Treasury
On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more
9/30/2019
/ Acquisitions ,
Built-In Gains ,
Change in Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Section 382 ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
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
The Internal Revenue Service (IRS) and Treasury Department today issued a much-welcomed technical correction to the effective date of the recently issued “built-in gain” regulations regarding real estate investment trust...more