News & Analysis as of

Final Rules Regulatory Requirements Tax Liability

McDermott Will & Emery

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

McDermott Will & Emery on

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

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on

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

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Holland & Knight LLP

IRS Releases Final Regulations on Reissuance and Retirement of Tax-Exempt Tender Option Bonds

Holland & Knight LLP on

The IRS released on Dec. 30, 2024, final regulations on Sections 1.150-3 and 1.1001-3(a)(2) (the Regulations) regarding the reissuance and retirement (debt extinguishment) of tax-exempt tender option bonds....more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

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