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Proposed Regulation Corporate Taxes

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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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

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

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In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

McDermott Will & Emery

Weekly IRS Roundup May 20 – May 24, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup April 1 – April 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024....more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

McDermott Will & Emery

Weekly IRS Roundup February 19 – February 23, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 19, 2024 – February 23, 2024. February 20, 2024: The IRS published Announcement 2024-12, which...more

Holland & Knight LLP

Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?

Holland & Knight LLP on

En este episodio de "A Lo Legal En Par Minutos", nuestro abogado Edwin Cortés conversa con Gustavo Pardo, socio del área tributaria, sobre el impacto de la reforma tributaria de 2022 en Colombia. Nuestros abogados abordan...more

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

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On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

McDermott Will & Emery

Weekly IRS Roundup December 25 – December 29, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 25, 2023 – December 29, 2023...more

McDermott Will & Emery

New York Formally Adopts Corporate Tax Reform Regulations

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On December 27, 2023, the New York State Department of Taxation and Finance (Department) adopted corporate tax reform regulations addressing New York’s corporate tax reform effective in 2015. The adopted regulations are...more

McDermott Will & Emery

Weekly IRS Roundup December 11 – December 15, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 11, 2023 – December 15, 2023. ...more

McDermott Will & Emery

Weekly IRS Roundup November 20 – November 24, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 20, 2023 – November 24, 2023....more

Blank Rome LLP

New York State Formally Proposes Regulations Implementing 2014 Corporate Tax Reform

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On August 9, 2023, the New York State Department of Taxation and Finance (the “Department”) formally proposed Business Corporation Franchise Tax Regulations under the State Administrative Procedure Act (“SAPA”). The proposed...more

Eversheds Sutherland (US) LLP

New York moves to finalize corporate franchise tax regulations

On August 9, 2023, the New York State Department of Taxation and Finance (Department) submitted its draft corporate franchise tax regulations for publication in the State Register – a significant and necessary step in the...more

Hogan Lovells

Reorganizacje transgraniczne będą opiniowane przez Szefa KAS

Hogan Lovells on

W 2022 r. na stronie Rządowego Centrum Legislacji opublikowano projekt Ustawy o zmianie ustawy — Kodeks spółek handlowych oraz niektórych innych ustaw (dalej: „Projekt”). Zakłada on dodanie do Kodeksu Spółek Handlowych...more

Hogan Lovells

Cross-border reorganisations to be reviewed by the tax authorities

Hogan Lovells on

In 2022, a bill aimed at amending the Polish Commercial Companies Code and certain other Acts was published on the website of the Government Legislation Centre (hereinafter: the “Project”). The Project adds provisions to the...more

Cadwalader, Wickersham & Taft LLP

To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company...

U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more

Eversheds Sutherland (US) LLP

They have arrived: New York issues “final draft” corporate income tax apportionment regulations

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

A&O Shearman

Government Releases Final Tax Regulations on the Transition from Interbank Offered Rates

A&O Shearman on

On December 30, 2021, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (IRS) released a pre-publication version of final regulations (Treas. Reg. § 1.1001-6) addressing the principal tax...more

McDermott Will & Emery

Five Things a CFO of a Recently De-SPAC’ed Company Should Know About the Biden Made in America Tax Plan

McDermott Will & Emery on

CFOs of recently de-SPAC’ed* and newly public companies face significant challenges. High on the list is the recently released Made in America Tax Plan, through which the Biden administration proposed significant changes to...more

McDermott Will & Emery

Weekly IRS Roundup November 9 – November 13, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020... November 9, 2020: The IRS released Notice 2020-75...more

A&O Shearman

IRS and Treasury Issue Final Regulations Regarding Use of Consolidated Net Operating Losses

A&O Shearman on

On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code...more

A&O Shearman

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

Eversheds Sutherland (US) LLP

Second time’s the charm? New proposed section 163(j) regulations treat electing CFC groups as a single corporation and eliminate...

Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include: ..An election under which a controlled foreign corporation (CFC)...more

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