News & Analysis as of

Internal Revenue Code (IRC) Proposed Rules Income Taxes

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

Fox Rothschild LLP on

An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Final Digital Content and Cloud Transaction Regulations

On January 10, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations (the Final Regulations) regarding the classification of digital content transactions and cloud...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

McDermott Will & Emery

Six Takeaways: Utilization and Structuring For Section 45Q Carbon Capture Credits

McDermott Will & Emery on

The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more

McDermott Will & Emery

[Webinar] Utilization and Structuring For Section 45Q Carbon Capture Credits - June 11th, 12:30 pm EST

The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

Snell & Wilmer on

The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

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