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Internal Revenue Service Domestic Corporations

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
ASKramer Law

Energy Tax Credits For A New World Part V: Domestic Content Bonus Credits

ASKramer Law on

What is the purpose of the Domestic Content Bonus Credit? The Inflation Reduction Act (IRA) introduced the Domestic Content Bonus Credit to provide an additional credit amount to taxpayers that meet its requirements. The...more

Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

Fenwick & West LLP on

The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Dechert LLP

Stock Repurchase Excise Tax Regulations Finalized: Effect on RICs

Dechert LLP on

On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more

Latham & Watkins LLP

Final Regulations Issued on Domestically Controlled REIT Determinations and Energy Credit Transfers

Latham & Watkins LLP on

Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more

Eversheds Sutherland (US) LLP

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

Goodwin

IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

Goodwin on

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

Vinson & Elkins LLP on

On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Issue Proposed Regulations Regarding the Stock Buyback Excise Tax

On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more

Mintz - Employment Viewpoints

Corporations with 10 or More ISO or ESPP Reporting Obligations on Forms 3921 or 3922 Should Take Notice of Revised Electronic...

Each year, corporations that have employees who exercise incentive stock options (ISOs) as described under Section 422(b) of the Internal Revenue Code must file a Form 3921 with the IRS for each transfer of stock to those...more

A&O Shearman

Inflation Reduction Act: New Guidance on Domestic Content Bonus Credits

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On May 12, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2023-38 (the “Notice”) to provide guidance on the domestic content requirements under IRC sections 45, 45Y,...more

Paul Hastings LLP

IRS Issues Initial Guidance on Domestic Content Bonus Credit for Energy Projects

Paul Hastings LLP on

The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain renewable energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). The IRA additions included a new domestic...more

Vinson & Elkins LLP

Highly Anticipated Domestic Content Bonus Guidance Released

Vinson & Elkins LLP on

On May 12, 2023, the Department of the Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) issued Notice 2023-38 (the “Notice”), providing guidance on the rules taxpayers must satisfy to qualify for the...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Release Interim Guidance on the One-Percent Excise Tax on Stock Repurchases by Publicly Traded Companies

The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more

Dorsey & Whitney LLP

Inflation Reduction Act: New U.S. Excise Tax on Stock Repurchase Transactions Applicable to Certain Canadian Companies

Dorsey & Whitney LLP on

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more

Dorsey & Whitney LLP

Inflation Reduction Act: New Excise Tax Discourages Stock Repurchase Transactions

Dorsey & Whitney LLP on

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by...more

McDermott Will & Emery

Government Releases Final Regulations on FDII and GILTI Deduction

McDermott Will & Emery on

On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more

McDermott Will & Emery

Weekly IRS Roundup February 10 – 14, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Proskauer Rose LLP

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Moore & Van Allen PLLC

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

Moore & Van Allen PLLC on

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

Katten Muchin Rosenman LLP

New Proposed Rules Limit the Negative Tax Consequences of Section 956 "Deemed Dividends" - Certain Foreign Guarantees and Stock...

On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more

Patterson Belknap Webb & Tyler LLP

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

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