News & Analysis as of

Depreciation Internal Revenue Code (IRC)

Holland & Knight LLP

IRS: Use of "Attrition Allowance" to Calculate Rate Base Violates Normalization Consistency Rules

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Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....more

McDermott Will & Emery

Weekly IRS Roundup February 6 – February 10, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 6, 2023 – February 10, 2023...more

Holland & Knight LLP

Phasedown of Bonus Depreciation for Aircraft Begins in 2023

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This Holland & Knight alert explains the phasedown of bonus depreciation for aircraft beginning in 2023. Through 2022, bonus depreciation has been allowed for 100 percent of the cost of qualifying property (which generally...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 23, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more

Latham & Watkins LLP

IRS Clears the Way for Retrofitted Carbon Capture Projects

Latham & Watkins LLP on

In a new Revenue Ruling, the IRS addresses the scope, ownership, and placed-in-service date for carbon capture equipment. Key Points: ..Developers adding carbon capture equipment to an existing industrial facility now...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

Tarter Krinsky & Drogin LLP

Hatch-Waxman Litigation Costs Both Capital Expenditures And Ordinary Business Expenses

Under the Internal Revenue Code (“Code”) Section 162, ordinary and necessary business expenses are deductible, but Code Section 263 disallows a deduction for capital expenditures (“no deduction shall be allowed” for a capital...more

Whitman Legal Solutions, LLC

Re-Evaluating Real Estate Dispositions Under the Biden Tax Plan

How Real Estate Investment is Like Buying Violins - Real estate investors also frequently gradually increase in size and price of their assets. A real estate investor might start small with a single duplex. When they sell...more

Gould + Ratner LLP

New Stimulus Allows Faster Depreciation of Certain Residential Rental Property Held by Electing Real Property Trades or Businesses

Gould + Ratner LLP on

The stimulus package passed last month may help certain Electing Real Property Businesses by including a provision that allows a shorter depreciation period for residential rental property acquired prior to January 1, 2018. ...more

McDermott Will & Emery

CARES Act Update: IRS Details How to Benefit from the Fix to the Retail Glitch

McDermott Will & Emery on

Under the Tax Cuts and Jobs Act of 2017 (TCJA), qualified improvement property (QIP) was unintentionally classified as nonresidential real property and therefore did not qualify for bonus depreciation. The Coronavirus Aid,...more

Eversheds Sutherland (US) LLP

Expensing 2.0 – Treasury and the Internal Revenue Service thoughtfully consider comments on the proposed § 168(k) regulations and...

On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more

Foster Garvey PC

Now You See It – Now You Don’t. Like Magic, the City of Portland Disallows Depreciation Deductions Otherwise Allowable as a Result...

Foster Garvey PC on

Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more

Rosenberg Martin Greenberg LLP

The Good, the Bad, and the Yet to be Defined

The Tax Cuts and Jobs Act (“TCJA”) provided the most comprehensive update to the tax code in over two decades. Of the many changes the TCJA provided, Sections 1400Z-1 and 1400Z-2 of the IRC are of the most heavily discussed...more

Opportune LLP

Proposed Bonus Depreciation Regulations Favorable For Certain Energy Partnership Transactions

Opportune LLP on

President Trump signed into law the Tax Cuts and Jobs Act (the “TCJA”) on December 22, 2017. Included in the TCJA were amendments to IRC §168(k), which permits taxpayers to expense 100% of the costs of certain qualified...more

Eversheds Sutherland (US) LLP

The more things change the more things remain the same–temporary guidance regarding bonus depreciation rules under section 168(k)

Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Latham & Watkins LLP

Impact of the House Tax Reform Bill on the Renewable Energy Sector

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Bold proposal seeks changes to tax credits, depreciation, and corporate tax rates. Key Points: - Production Tax Credits are cut by more than one-third. - Bill may impact existing and future tax equity arrangements. ...more

Eversheds Sutherland (US) LLP

IRS Ruling Provides Helpful Guidance on Normalization Proration Rules 

On September 29, 2017, the IRS issued a private letter ruling (PLR 201739001) providing helpful guidance on the application of normalization proration rules for the calculation of accumulated deferred federal income taxes...more

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