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Corporate Taxes U.S. Treasury Tax Reform

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Brownstein Hyatt Farber Schreck

White House FY2025 Budget Request: Key Tax Takeaways

On Monday, March 11, President Joe Biden released his budget request to Congress (“Budget”) and various accompanying documents. Separately, the Treasury Department released its General Explanations of the Administration’s...more

Brownstein Hyatt Farber Schreck

Fiscal Year 2025 Greenbook Provisions Chart

On Monday, March 11, President Joe Biden released his budget request to Congress (“Budget”) and various accompanying documents. Separately, the Treasury Department released its General Explanations of the Administration’s...more

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Skadden, Arps, Slate, Meagher & Flom LLP

The 2024 Green Book and Tax Implications: A Primer

On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more

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

Cadwalader, Wickersham & Taft LLP

Notice 2023-7 Provides Initial Guidance Regarding the Corporate Alternative Minimum Tax

On December 27, 2022, Treasury issued Notice 2023-7, which provides guidance regarding the new Corporate Alternative Minimum Tax (“CAMT”) that taxpayers can rely on until Treasury publishes additional guidance. As mentioned...more

Foley & Lardner LLP

Tax Provisions in the Inflation Reduction Act of 2022

Foley & Lardner LLP on

On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process. The bill, named the Inflation Reduction Act of 2022, is expected to be taken up by the House of...more

McDermott Will & Emery

The Inflation Reduction Act: Overview of New Corporate Minimum Tax

McDermott Will & Emery on

On August 7, 2022, the US Senate passed the Inflation Reduction Act of 2022 (the Act), a budget reconciliation bill recently introduced by Senate Majority Leader Chuck Schumer (D-NY) and Senator Joe Manchin (D-WV). The bill...more

Brownstein Hyatt Farber Schreck

Brownstein Invites You to Submit Comments for IRS Priority Guidance Plan

On April 26, the Internal Revenue Service (IRS) released Notice 2022-32, inviting the public to make recommendations regarding items to include in the 2022-2023 Priority Guidance Plan (PGP)....more

Gray Reed

Ending Corporate Greed Act & Build Back Better Act – Two Proposals for Increasing Revenue

Gray Reed on

On March 25, 2022, Senator Bernie Sanders (I-VT) introduced a new bill, “Ending Corporate Greed Act”, which coincides close in time with the release of Treasury’s Green Book, “General Explanations of the Administration’s...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, January 11, 2022

Tax Tidbit - Budget Reconciliation: By the Numbers. Since 1980, Congress has passed 26 budget reconciliation bills, 22 of which have become law. During 11 of those 41 years, Congress did not pass any budget reconciliation...more

McDermott Will & Emery

Weekly IRS Roundup September 20 – 24, 2021

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 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more

Foodman CPAs & Advisors

2021 “Green Book” Introduces Comprehensive Financial Account Reporting

The “Green Book” is a US Treasury Department document that presents detailed explanations of an Administration’s revenue proposals in support of a President’s annual budget request.  On May 28, 2021, the Biden administration...more

Proskauer - Tax Talks

Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

Proskauer - Tax Talks on

On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

Holland & Knight LLP on

A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

Holland & Knight LLP on

By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Eversheds Sutherland (US) LLP

Changing the BEAT - Final regulations answer key questions, proposed regulations give new relief

A year after the initial proposed BEAT regulations were released, Treasury and the IRS have issued a package of final and proposed regulations under § 59A of the Internal Revenue Code of 1986, as amended (the Code), the...more

Wilson Sonsini Goodrich & Rosati

Corporate Tax 2019 - Seventh Edition - USA Chapter

Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019

In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more

Womble Bond Dickinson

US Tax Reform for Exporters that Both North Carolina Manufacturers and Triangle High Tech Businesses Can Love

Womble Bond Dickinson on

The 2017 Tax Cut and Jobs Act (“TCJA”) introduced a number of provisions that fundamentally change the way that the US taxes income from the foreign operations of US groups. One of the more favorable TCJA provisions provides...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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