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Internal Revenue Code (IRC) U.S. Treasury

Cadwalader, Wickersham & Taft LLP

New York State Bar Association Tax Section Proposes Withdrawal of Proposed Spin-Off Regulations

On March 17, the Tax Section of the New York State Bar Association (the “Tax Section”) released a report on the proposed regulations on corporate spin-offs and reorganizations that were issued in January. As we discussed...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

McDermott Will & Emery on

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Vedder Price

Regulations Requiring DeFi Platforms to Report Tax Information Nullified by Congress

Vedder Price on

On March 11, 2025, under the auspices of the Congressional Review Act (CRA), the U.S. House of Representatives approved a joint resolution (H.J. Res. 25) officially disapproving of recently finalized regulations that would...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

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Vinson & Elkins LLP

Tax Law (and Controversy) Under the Trump Administration

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As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more

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

Morgan Lewis

Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...more

McDermott Will & Emery

Lawmakers Revisit Tax Treatment of Carried Interest

McDermott Will & Emery on

The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...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

Orrick, Herrington & Sutcliffe LLP

Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program

The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as...more

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Holland & Knight LLP

Final Regulations on IRS Appeals Issued

Holland & Knight LLP on

In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more

Akin Gump Strauss Hauer & Feld LLP

America First Trade Policy (Trump EO Tracker)

Requires a variety of reports and recommendations to be delivered to the President by April 1, 2025: on the causes of the persistent trade deficit, how to establish the External Revenue Service, unfair foreign trade...more

Orrick, Herrington & Sutcliffe LLP

New IRS Guidance on Domestic Content Bonus Credit

The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced...more

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

Fox Rothschild LLP on

President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more

Orrick, Herrington & Sutcliffe LLP

Tech-Neutral Credits Final Regulations Released for Clean Electricity Production

The U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) have released final regulations for two new tax credits under the Internal Revenue Code (Code), established by the Inflation Reduction Act...more

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on

On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

Orrick, Herrington & Sutcliffe LLP

Treasury and IRS Release Guidance on Clean Fuel Production Credit

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released a notice of intent to propose regulations and a notice providing the annual emissions rate table for the Clean Fuel...more

Latham & Watkins LLP

Treasury Circulates Draft Regulations for Section 45Z Clean Fuel Production Credit

Latham & Watkins LLP on

A new tax credit is proposed to calculate a fuel’s emissions factor based on its full carbon life cycle of production. Notices 2025-10 and 2025-11 (Notices), released on January 10, 2025, outline the intention of the...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

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

Ballard Spahr LLP

Your Role in Protecting Tax-Exempt Bonds During Legislative Changes

Ballard Spahr LLP on

President Trump has indicated that one of his key economic priorities is to extend the expiring provisions of the Tax Cuts and Jobs Act (TCJA). However, Congress still needs to resolve disagreements on the cost and funding of...more

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