News & Analysis as of

Corporate Taxes Tax Deductions New Guidance

Eversheds Sutherland (US) LLP

A wolf in sheep’s clothing? IRS provides long-awaited capitalization guidance for natural gas companies

In recently issued Rev. Proc. 2023-15, the IRS provides a safe harbor method of accounting under which taxpayers may classify costs to repair, maintain, replace, or improve natural gas transmission and distribution property...more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

Goodwin on

On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – 22, 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 November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

McDermott Will & Emery

Weekly IRS Roundup September 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 September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...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

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

Latham & Watkins LLP

IRS Provides Initial Guidance on Section 162(m) Tax Reform Changes

Latham & Watkins LLP on

Notice 2018-68 clarifies certain Section 162(m) issues with respect to covered employees and grandfathering of written binding contracts. Key Points: ..“Covered employee” determination is not affected by whether or not...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

Eversheds Sutherland (US) LLP

Think twice before deducting success-based fees - new Chief Counsel Advice denies deduction of success-based fee due to lack of...

On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more

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