News & Analysis as of

Internal Revenue Code (IRC) Domestic Corporations

Frost Brown Todd

To Be Clear…LLCs Can Issue Qualified Small Business Stock (QSBS)

Frost Brown Todd on

Since the finalization of the IRS’s “check-the-box” entity-classification regulations nearly 30 years ago, a state law LLC can elect to be taxed an association taxable as a corporation. During the past month, we have heard...more

Goodwin

IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

Goodwin on

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

Vinson & Elkins LLP on

On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

Mintz - Employment Viewpoints

Corporations with 10 or More ISO or ESPP Reporting Obligations on Forms 3921 or 3922 Should Take Notice of Revised Electronic...

Each year, corporations that have employees who exercise incentive stock options (ISOs) as described under Section 422(b) of the Internal Revenue Code must file a Form 3921 with the IRS for each transfer of stock to those...more

Vinson & Elkins LLP

Highly Anticipated Domestic Content Bonus Guidance Released

Vinson & Elkins LLP on

On May 12, 2023, the Department of the Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) issued Notice 2023-38 (the “Notice”), providing guidance on the rules taxpayers must satisfy to qualify for the...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...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

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Patterson Belknap Webb & Tyler LLP

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

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