News & Analysis as of

Internal Revenue Code (IRC) Proposed Regulation

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

Implementation of Section 45Z/Clean Fuels Production Credit: Energy Marketers of America Comments on Internal Revenue Service's...

The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more

Faegre Drinker Biddle & Reath LLP

(Auto) Enroll With It: Understanding the New Automatic Enrollment Requirements

On January 10, 2025, the Treasury Department and the Internal Revenue Service issued Proposed Regulations on the automatic enrollment requirements introduced by SECURE 2.0.  The Proposed Regulations incorporate and expand...more

McCarter & English, LLP

Proposed Corporation Business Tax Regulations, Proposing Sweeping Changes, Published in ‘New Jersey Register’

On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...more

Davis Wright Tremaine LLP

New Guidance Issued on Mandatory and Optional Catch-Up Provisions Under SECURE 2.0

New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more

Morgan Lewis - ML Benefits

IRS Proposes Regulations on Expanded Definition of Covered Employee Under Code Section 162m

Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more

Goodwin

Internal Revenue Code Section 162(m): Proposed Regulations

Goodwin on

On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more

ArentFox Schiff

Proposed Legislation Targets Nonprofits Supporting Immigrant Communities

ArentFox Schiff on

Proposed legislation introduced in the US Senate last week would deny tax-exempt status to certain organizations that support undocumented immigrants. The legislation would change the eligibility requirements for 501(c)(3)...more

Morgan Lewis

IRS Issues Proposed Regulations on SECURE 2.0 Catch-Up Contribution Changes – Publications

Morgan Lewis on

The Internal Revenue Service (IRS) issued proposed regulations providing guidance on how to interpret and implement changes to "catch-up" contributions made by the SECURE 2.0 Act of 2022 (SECURE 2.0). The regulations mainly...more

Miller Canfield

IRS Issues Proposed Regulations on Secure 2.0 Catch-Up Provisions

Miller Canfield on

The IRS issued Proposed Regulations last month which provide helpful clarity for employers on how to implement and comply with two new SECURE 2.0 provisions relating to catch-up contributions....more

Cooley LLP

Proposed Regulations Issued Under Internal Revenue Code § 162(m)

Cooley LLP on

Changes effective starting on January 1, 2027 - In the last few days preceding President Donald Trump’s inauguration, the IRS under the Biden administration proposed regulations to implement amendments to Internal Revenue...more

Eversheds Sutherland (US) LLP

Proposed regulations explain the expansion of “covered employees” under Code Section 162(m)

On January 14, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations (Proposed Regulations) relating to the expansion of the definition of “covered employees” under Internal Revenue...more

McDermott Will & Emery

IRS Roundup January 13 – 17, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more

Cooley LLP

Treasury Department Issues Final and Proposed Rules on Cloud Transactions, Other Digital Content

Cooley LLP on

On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more

Troutman Pepper Locke

IRS Issues Proposed Regulations on the Expanded Definition of "Covered Employee" Under Code Section 162(m)

Troutman Pepper Locke on

On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more

Jones Day

New Guidance on the Commercial EV Tax Credit

Jones Day on

In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more

Groom Law Group, Chartered

IRS Issues Proposed Regulations Implementing Changes to Code Section 162(m)

On January 14, 2025, the Internal Revenue Service (“IRS”) and the Department of Treasury issued proposed regulations under Internal Revenue Code (“Code”) section 162(m), which limits the deductibility of certain employee...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

Jones Day on

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

A&O Shearman

Proposed regulations provide guidance regarding certain aspects of spinoffs and reorganizations

A&O Shearman on

On January 13, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-112261-23 and REG-112261-24) adding and amending parts of the regulations...more

Pillsbury Winthrop Shaw Pittman LLP

Initial Guidance on Clean Fuel Production Credit Under IRC Section 45Z

On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan to issue with respect to...more

Nutter McClennen & Fish LLP

IRS Issues New Proposed Regulations Under 162(m)

On January 14, 2025, the Internal Revenue Service (the “IRS”) issued new proposed regulations under section 162(m) of the Internal Revenue Code (the “Code”), supplementing regulations already in effect. Under section 162(m),...more

Cadwalader, Wickersham & Taft LLP

IRS and Treasury Issue Proposed Regulations on Tax-Free Reorganizations, Spin-Offs

On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.  The IRS and...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (6): Automatic Enrollment (5) and PEPs

SECURE 2.0 was enacted on December 29, 2022. Among its provisions is a requirement that “new” 401(k) plans and private sector 403(b) plans must automatically enroll their eligible employees, but not until the first plan year...more

Groom Law Group, Chartered

IRS Issues Much Anticipated Guidance on Catch-Up Contributions

On January 10, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations regarding the provisions of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) that relate to...more

McAfee & Taft

New year = New proposed rules impacting retirement plans

McAfee & Taft on

The Internal Revenue Service has been busy. On Friday, January 10, 2025, the IRS issued several notices of proposed rulemaking impacting qualified retirement plans. One set of proposed rules adds to the SECURE 2.0 requirement...more

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