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Income Taxes › U.S. Treasury

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Eversheds Sutherland (US) LLP on

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

McDermott Will & Emery

Weekly IRS Roundup August 5 – August 9, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more

Holland & Knight LLP

Treasury Department Confirms Suspension of U.S.-Russia Income Tax Treaty

Holland & Knight LLP on

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more

Foodman CPAs & Advisors

High Income High Wealth Taxpayers Pursued By IRS

Foodman CPAs & Advisors on

On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more

Freeman Law

Proposed Regulations on Loans of Cash and Property from Foreign Trusts

Freeman Law on

On May 8, 2024, the Treasury Department issued proposed regulations regarding the classification, taxation, and reporting of foreign trusts. The proposed regulations were issued for sections 643(i), 679, 6039F, 6048, and 6677...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Energy Credits under the Inflation Reduction Act: What do you need to know?

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Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

McNees Wallace & Nurick LLC on

The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

Katten Muchin Rosenman LLP

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations for Some US Taxpayers

Katten Muchin Rosenman LLP on

It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more

Morgan Lewis

Treasury and the IRS Finalize Section 897 ‘Domestically Controlled’ Look-Through Rule

Morgan Lewis on

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more

Pillsbury Winthrop Shaw Pittman LLP

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

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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

King & Spalding on

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

Eversheds Sutherland (US) LLP

Treasury and IRS release final regulations on elective payment election under CHIPS Act Section 48D

Eversheds Sutherland (US) LLP on

On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more

Rivkin Radler LLP

An Inveterate Golfer At the IRS

Rivkin Radler LLP on

As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022...more

K&L Gates LLP

The Department of Treasury Releases Direct Pay Guidance on Clean Energy Tax Credits

K&L Gates LLP on

Final Rules Address Eligibility and Process; Proposed Rules Provide Workaround Allowing Tax Exempts to Partner With Others on Projects - The Department of Treasury (Treasury) and the Internal Revenue Service (IRS) recently...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

Rivkin Radler LLP on

Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

Brownstein Hyatt Farber Schreck

Fiscal Year 2025 Greenbook Provisions Chart

Brownstein Hyatt Farber Schreck on

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

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

Paul Hastings LLP on

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

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Troutman Pepper

IRS Issues Final Regulations on Direct Pay

Troutman Pepper on

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Lead Service Lines/Drinking Water: Internal Revenue Service Determination Addressing Exemption of Replacement Cost

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The United States Internal Revenue Service (“IRS”) addressed the federal income tax treatment of certain lead service line replacement programs for residential property owners. See announcement 2024-10....more

Allen Barron, Inc.

US Treasury Says IRS is Focused on Tax Evasion Targeting

Allen Barron, Inc. on

The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

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On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

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In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

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