News & Analysis as of

Final Rules U.S. Treasury Proposed Regulation

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Foley & Lardner LLP

IRS Releases Final Regulations Under Section 48 of the Code

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) and Department of the Treasury last week released final regulations (the “Final Regulations”) relating to investment tax credits under Section 48 of the (the “ITC”) of the Internal Revenue...more

Bracewell LLP

Treasury and IRS Issue Final and Proposed Regulations Expanding Applicable Entities’ Ability to Elect Direct Pay in Connection...

Bracewell LLP on

On November 19, 2024, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 761 (the Final Regulations) enabling certain entities to make a direct pay...more

Eversheds Sutherland (US) LLP

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final ‘Domestically Controlled REIT’ Regulations Retain Corporate Look-Through With Some Modifications

On April 24, 2024, the Treasury Department released final regulations that alter key rules affecting many real estate funds and foreign investors in U.S. real estate....more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - October 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

ArentFox Schiff

No More Surprise Medical Bills: Biden Administration Issues New Rule Governing Arbitration Fees and Takes First Step to Restarting...

ArentFox Schiff on

On September 21, 2023, the US Departments of Treasury (DOT), Labor (DOL), and Health and Human Services (HHS) (the Departments) issued new rulemaking governing the administrative fee required to access the arbitration process...more

King & Spalding

IRS Proposed Regulations and DOL Guidance Clarify Certain Aspects of the Prevailing Wage and Apprenticeship Requirements

King & Spalding on

The U.S. Department of Treasury (“Treasury”) and IRS issued proposed regulations (“Proposed Regulations”) on August 29, 2023, regarding increased credit or deduction amounts available under the Inflation Reduction Act of 2022...more

Bracewell LLP

IRS and Treasury Department Release Last Set of Final Regulations on Bonus Depreciation

Bracewell LLP on

On September 21, 2020, the IRS and Treasury Department released the last set of final regulations (the 2020 Final Regulations) under the bonus depreciation rules of Section 168(k) of the Internal Revenue Code (the Code). ...more

ArentFox Schiff

CFIUS 2.0: Mandatory Filings Now Pegged to Export Control Rules

ArentFox Schiff on

The Committee on Foreign Investment in the United States (CFIUS) is now following new rules on mandatory filings for certain foreign investments in critical technology companies. As a refresher, CFIUS is the US Government’s...more

Bracewell LLP

Final Regulations and New Proposed Regulations on Immediate Expensing: Implications for Energy and Infrastructure

Bracewell LLP on

On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more

McDermott Will & Emery

Weekly IRS Roundup February 10 – 14, 2020

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 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Releases Final Regulations Implementing CFIUS Reform

Key Points - On January 13, 2020, the U.S. Department of Treasury released final rules implementing FIRRMA, which reforms the CFIUS framework. These rules will take effect on February 13, 2020. - The final rules...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

Fenwick & West LLP

Final and Proposed New BEAT Regulations Contain Important Changes

Fenwick & West LLP on

The final Base Erosion and Anti-Abuse Tax regulations recently approved in T.D. 9885 generally follow the December 21, 2018, proposed regulations with a few important changes. The IRS also issued new proposed regulations at...more

A&O Shearman

Treasury and IRS Issue Final Regulations on Base Erosion and Anti-Abuse Tax (The BEAT)

A&O Shearman on

On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more

McDermott Will & Emery

Weekly IRS Roundup October 21 – 25, 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 October 21 – 25, 2019. October 21, 2019: The IRS issued a news release in which it announced the...more

Troutman Pepper Locke

Final Regulations Issued for Hardship Distributions From Qualified Retirement Plans

Troutman Pepper Locke on

As we wrote in November 2018, the Treasury Department issued proposed regulations that significantly relaxed many rules governing hardship distributions from qualified plans, including eliminating requirements that employee...more

Jones Day

New Immediate Expensing Regulations Present Opportunities and Questions - Following up on 2018 proposed regulations, the...

Jones Day on

The Treasury Department and Internal Revenue Service have issued final and proposed regulations (collectively, the new regulations) under section 168(k) of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

McDermott Will & Emery

Weekly IRS Roundup June 10 – 14, 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 June 10 – 14, 2019. June 11, 2019: The IRS issued a news release noting that it and the US...more

King & Spalding

Foreign Guarantees and Collateral in Play Following Finalization of Deemed Dividend Regulations

King & Spalding on

On May 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more

Akin Gump Strauss Hauer & Feld LLP

New Partnership Liability and Disguised Sale Regulations

Key Points - - Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more

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