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Internal Revenue Code (IRC) Penalties U.S. Treasury

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...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

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Holland & Knight LLP on

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

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

Long Awaited Elective Payment Election Final Regulations and Other Guidance Issued by Treasury Department and IRS

On March 5, 2024, the U.S. Department of Treasury and Internal Revenue Services (IRS) released final regulations regarding the direct payment election under the Inflation Reduction Act of 2022 (IRA), a tax credit monetization...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations on the Prevailing Wage and Apprenticeship Requirements under the Inflation...

The proposed regulations adopt the Department of Labor’s published rates for prevailing wages for the relevant type of construction in the geographic location of the project. The proposed regulations provide additional...more

Latham & Watkins LLP

US Tax Court Voids Penalties Affecting Syndicated Conservation Easements; Treasury Reacts With Proposed Regulations

Latham & Watkins LLP on

The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations Address Disallowance of Deductions for Fines, Penalties and Other Amounts

On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more

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