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Asset Transfer Internal Revenue Service U.S. Treasury

Cadwalader, Wickersham & Taft LLP

New Proposed 'Killer B' Regulations Reduce Compliance Sting

On October 5, the U.S. Treasury released long-awaited proposed regulations regarding inbound cross-border reorganizations, implementing (with modifications) policies that had been announced in 2014 and 2016 notices. These...more

Paul Hastings LLP

Treasury and IRS Issue Long-Awaited Guidance on Energy Tax Credit Transfers

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more

BakerHostetler

Overview of the Proposed Regulations Addressing Transferring Renewable Credits

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

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

Eversheds Sutherland (US) LLP

To the Direct Acquirer Belong the Tax Attributes: Proposed Regulations Modify the Definition of Acquiring Corporation for Purposes...

On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more

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