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Final Rules Income Taxes

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

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The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

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Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

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On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

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Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

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On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

Freeman Law

Treasury Issues Final Digital Asset Sourcing Regs and Proposed Cloud Transaction Sourcing Regs

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On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions. Why is Source Important? While U.S. persons generally are...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Final Digital Content and Cloud Transaction Regulations

On January 10, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations (the Final Regulations) regarding the classification of digital content transactions and cloud...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Holland & Knight LLP

Final Regulations Issued on Penalty Supervisory Approval

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More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

PilieroMazza PLLC

SBA Update: Final Rule Appears Beneficial for IT Value-Added Resellers

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As PilieroMazza covered on December 17, 2024, SBA issued its much-anticipated final rule in response to the proposed rule it issued in August and the hundreds of public comments it received.  One area of particular interest...more

Baker Botts L.L.P.

Form SD Deadline Approaching for Resource Extraction Issuers: Reminder and FAQs

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As previously discussed in our Client Alert issued on December 18, 2020 (available here), the U.S. Securities and Exchange Commission (the “Commission”) adopted its final rule (the “Final Rule,” available here) requiring...more

Davies Ward Phillips & Vineberg LLP

IRS Relaxes Rules for Domestically Controlled REITs

Non-U.S. investors are generally subject to U.S. federal income tax on gains from investments in private U.S. real estate investment trusts (REITs). Two exceptions (among others) are for investments in “domestically...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

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On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Troutman Pepper Locke

IRS Issues Final Regulations on Direct Pay

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On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more

McDermott Will & Emery

Weekly IRS Roundup January 15 – January 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup November 6 – November 10, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023...more

McDermott Will & Emery

Weekly IRS Roundup December 12 – December 16, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update—FinCEN Issues Final Rule

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued the highly anticipated final rule, Beneficial Ownership Information Reporting Requirements (the “Final Rule”), implementing the beneficial...more

Sullivan & Worcester

Massachusetts Brownfields Tax Credit

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In a bid to rehabilitate the Brownfields Tax Credit ("BTC") application and approval process, the Massachusetts Department of Revenue ("DOR") has issued final regulations (830 CMR 63.38Q.1) and new administrative procedures...more

Goodwin

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

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In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

Bowditch & Dewey

Update on Revised DOR Income Tax Pandemic Regulations for Telecommuters

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On March 5, 2021, the Massachusetts Department of Revenue (DOR) codified final regulations to extend Massachusetts income tax withholding to non-residents formerly commuting to Massachusetts but now telecommuting due to the...more

Bracewell LLP

Broad Federal Support for Carbon Capture, Utilization and Storage May Lead to Greater Investment

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Federal support for carbon capture, utilization and storage (“CCUS”) demonstrated over the last two months has generated even greater enthusiasm for carbon capture projects in the United States. First, in the final weeks of...more

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