News & Analysis as of

Proposed Regulation Revenue Procedures

Eversheds Sutherland (US) LLP

Short tax year savior: Rev. Proc. 2024-34

Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes - On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....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

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

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

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

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations and Revenue Procedure on the Clean Vehicle Tax Credits under Section 30D of...

The proposed regulations add new definitions to clarify what is required under foreign entity of concern (FEOC) compliance. The Revenue Procedure provides guidance to qualified manufacturers on reporting and other...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

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The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...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

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations and Procedures for Clean Vehicle Credit Transfers

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The U.S. Department of the Treasury and IRS on Oct. 6, 2023, released proposed regulations on the transfer of clean vehicle credits under Internal Revenue Code Section 25E (for previously owned clean vehicles) and Section 30D...more

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

McDermott Will & Emery

Weekly IRS Roundup April 24 – April 28, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 – April 28, 2023...more

Eversheds Sutherland (US) LLP

The Superfun(d) continues! IRS issues comprehensive Superfund chemical excise tax guidance

On March 27, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued much anticipated proposed regulations, REG-105954-22 (Proposed Regulations), and additional guidance in the form of Revenue...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

McDermott Will & Emery

Weekly IRS Roundup November 21 – November 25, 2022

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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 21, 2022 – November 25, 2022...more

McDermott Will & Emery

IRS Appeals Will Not Consider Regulatory Invalidity and Subregulatory Procedural Invalidity Challenges

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In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like they do to other federal agency...more

McDermott Will & Emery

Weekly IRS Roundup July 25 – July 29, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more

McDermott Will & Emery

Weekly IRS Roundup April 24 – April 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2022 – April 30, 2022... April 25, 2022: The IRS issued a news release, soliciting...more

Eversheds Sutherland (US) LLP

Anticipating the end: IRS finalizes LIBOR transition guidance

Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more

McDermott Will & Emery

Weekly IRS Roundup December 28, 2020 – January 8, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021... December 29, 2020: The IRS released Revenue Procedure...more

McGuireWoods LLP

IRS Revenue Procedure 2020-44: Floating Rate Fallback Flexibility from the Feds

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The IRS recently released Revenue Procedure 2020-44 (“Rev. Proc. 2020-44”) which provides helpful relief to taxpayers by providing that if a contract referencing an IBOR is modified to incorporate specific ISDA or AARC...more

Williams Mullen

IRS Issues Compliance Regulations for LIHTC Projects and COVID-19 Relief

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On July 1, 2020, the IRS issued proposed regulations (REG-123027-19; RIN 1545-BP59) (Regulations) governing compliance-monitoring for low-income housing tax credit (LIHTC) projects and issued Notice 2020-53 (Notice) in...more

Lathrop GPM

IRS Proposes New Rules Regarding Group Exemptions

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The IRS allows a “central organization” to obtain a group exemption letter that permits a central organization’s “subordinate organizations” to obtain recognition of their tax-exempt status without applying to the IRS. In...more

BCLP

Proposed changes to group exemption letter program, UBTI ‘silo’ rules and more

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IRS solicits public comments on proposed changes to group exemption letter program; will temporarily stop accepting requests for group exemption letters on June 17, 2020 - Notice 2020-36 contains a proposed revenue...more

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