News & Analysis as of

Corporate Taxes New Guidance Tax Cuts and Jobs Act

Eversheds Sutherland (US) LLP

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

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 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 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Laner Muchin, Ltd.

IRS Shows How Difficult It Can Be To Exclude Business Meals From Income

Laner Muchin, Ltd. on

The IRS recently issued a Technical Advice Memorandum (TAM) demonstrating the level of scrutiny that the IRS will apply in the case of the business meal exclusion....more

Katten Muchin Rosenman LLP

Considerations and Challenges Under New IRS Guidance on Section 162(m)

On August 21, the IRS issued Notice 2018-68, Guidance on the Application of Section 162(m) ("Notice"). Internal Revenue Code ("Code") Section 162(m) places a limitation on the amount publicly traded companies are permitted to...more

Cadwalader, Wickersham & Taft LLP

New IRS Guidance Regarding Section 162(m)’s Deduction Limitation for Executive Compensation – Increased Complexity and Reduced...

The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more

Snell & Wilmer

The IRS’ Initial 162(m) Transition Guidance is Finally Here

Snell & Wilmer on

On August 21, 2018, the IRS released Notice 2018-68 (“Notice”) providing its initial guidance on the Tax Cuts and Jobs Act (“Act”) transition rule for changes made to Section 162(m) of the Internal Revenue Code of 1986, as...more

Brownstein Hyatt Farber Schreck

IRS Guidance Clarifies Some TCJA Changes to the $1 Million Deduction Limit for Executive Compensation under Code Section 162(m)

Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”), limits a publicly held corporation’s ability to take a corporate income tax deduction for compensation in excess of $1 million paid to “covered...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Permissibility of State Legislation to Circumvent SALT Deduction Cap

On Aug. 23, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under Section 170 of the Internal Revenue Code (Code) addressing the federal income tax treatment...more

Snell & Wilmer

The 162(m) Transition Rule Guidance Has Arrived

Snell & Wilmer on

On August 21, 2018, the IRS released Notice 2018-68 providing its initial guidance on the Tax Cuts and Jobs Act (Act) transition rule for changes under 162(m). Before the Act, 162(m) limited a public company’s tax deduction...more

Latham & Watkins LLP

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

Latham & Watkins LLP on

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

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