News & Analysis as of

Internal Revenue Code (IRC) U.S. Treasury New Regulations

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

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Jones Day

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

Jones Day on

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

Mayer Brown on

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

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

Treasury, Internal Revenue Service Issue Final Regulations for Transfer of Energy Credits

On April 25, 2024, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations regarding the transfer of energy tax credits under the Inflation Reduction Act of 2022 (IRA)....more

Mayer Brown

US Treasury Releases Final Regulations Addressing Domestic Control Determinations Under FIRPTA

Mayer Brown on

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more

Fenwick & West LLP

IRS Delays Infrastructure Act's Broker Reporting Requirements

Fenwick & West LLP on

On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Mintz - Public Finance Viewpoints

Treasury and IRS Release Final Tax Regulations for LIBOR Replacement Amendments

The lengthy saga of the transition to a post-LIBOR world reached a degree of finality on the tax side with the issuance by the Department of Treasury and Internal Revenue Service (IRS) of long-awaited final regulations (the...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Bracewell LLP

IRS and Treasury Department Release Final Regulations Regarding Like-Kind Exchanges

Bracewell LLP on

On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of...more

McDermott Will & Emery

Government Releases Second Tranche of Final Regulations on BEAT

McDermott Will & Emery on

On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...more

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

Fenwick & West LLP on

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

Eversheds Sutherland (US) LLP

Expensing 2.0 – Treasury and the Internal Revenue Service thoughtfully consider comments on the proposed § 168(k) regulations and...

On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Facilitate Foreign Subsidiary Credit Support

On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more

McDermott Will & Emery

Treasury Finalizes Regulations on the Varying Interests Rule Under Section 706

McDermott Will & Emery on

On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

McDermott Will & Emery

Treasury and IRS Issue New Temporary Treasury Regulations

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

McDermott Will & Emery

Treasury Releases Guidance for Contributions of Appreciated Property to Partnerships with Related Foreign Partners

McDermott Will & Emery on

On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Challenging the IRS Anti-Inversion Notice: A Hollow Threat"

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...more

Eversheds Sutherland (US) LLP

New Final Regs on Use of Differential Income Stream in Evaluating Cost-Sharing Arrangements

On August 26, 2013, the United States Treasury Department issued new final regulations under Internal Revenue Code (IRC) Section 482. The new regulations provide guidance on the “income method” for determining taxable income...more

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