News & Analysis as of

Rebuttable Presumptions Proposed Regulation

Holland & Knight LLP

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

Holland & Knight LLP on

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

Latham & Watkins LLP

DOI Seeks Comments on Proposal to Expand Natural Resource Damage Assessment Procedures

Latham & Watkins LLP on

The advanced notice of proposed rulemaking signals DOI’s interest in developing faster and more cost-effective methods to quantify natural resource damage claims. On January 18, 2023, the US Department of the Interior...more

McDermott Will & Emery

Ninth Circuit Allows IRS to Overrule Common-Law Mailbox Rule

McDermott Will & Emery on

Most tax professionals are aware of the common-law “mailbox rule,” which provides that proof of proper mailing creates a rebuttable presumption that the document was physically delivered to the addressee. Internal Revenue...more

Morrison & Foerster LLP

IRS Issues Final Debt-Equity Regulations

Morrison & Foerster LLP on

On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more

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