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Corporate Taxes Internal Revenue Service Safe Harbors

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Latham & Watkins LLP

Treasury and IRS Issue Initial Guidance on Stock Buyback Tax and Corporate Minimum Tax

Latham & Watkins LLP on

New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more

Robins Kaplan LLP

Financial Daily Dose 2.10.2020 | Top Story: Volvo May go Public Via Merger With Owner’s Geely Automobile Holdings

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Volvo’s owner, Li Shufu, is mulling over a move to combine the carmaker with his publicly traded Geely Automobile Holdings—a play that would take Volvo public and “unify the bulk of billionaire Li’s growing stable of...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Proskauer - Tax Talks

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

Proskauer - Tax Talks on

On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on

While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Brownstein Hyatt Farber Schreck

Taxation & Representation - September 24, 2018

TAX TIDBIT - With the midterm elections just weeks away, both parties have been hitting the campaign trail hard, strutting their stuff to win over voters. ...more

Miller Canfield

IRS Safe-Harbor to Calculate Federal Income Tax Credits for Research Expenses

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A taxpayer may claim a credit against its federal income tax liability for research expenses paid or incurred during the tax year. The definitions of research expenses for financial reporting purposes and federal income...more

Foley & Lardner LLP

The GOP’s Tax Cuts and Jobs Act Includes Changes Impacting the Renewable Energy Industry

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On November 3rd, House Ways and Means Committee Chairman Kevin Brady (R. Tex.) released the “chairman’s mark” to H.R. 1, the “Tax Cuts and Jobs Act” (TCJA). The TCJA represents the most extensive rewrite of the Internal...more

Miles & Stockbridge P.C.

IRS Issues New Guidance on TIGER Grants

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services. Section 118...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

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For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

McDermott Will & Emery

IRS Updates EPCRS Correction Methods and Procedures

Reflecting comments it requested, and others it received, the Internal Revenue Service (IRS) recently issued two updates which modify the Employee Plans Compliance Resolution System (EPCRS), which is the comprehensive system...more

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