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
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
El 29/08/23, el IRS emitió un Aviso de Reglamentación Propuesta y un Aviso de Audiencia Pública para las regulaciones propuestas sobre los activos digitales. Las Regulaciones Propuestas de Activos Digitales del IRS abordan el...more
On 8/29/23, the IRS issued a Notice of Proposed Rulemaking and Notice of Public Hearing for Digital Assets Proposed Regulations. The IRS Digital Assets Proposed Regulations address information reporting, the determination...more
The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more
Section 45Q, as amended by the Bipartisan Budget Act of 2018 (BBA), provides a substantial tax credit for the capture and sequestration of carbon dioxide and other carbon oxides. Taxpayers have been awaiting guidance from the...more
In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more