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Foley & Lardner LLP

Tax Provisions in the Inflation Reduction Act of 2022

Foley & Lardner LLP on

On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process. The bill, named the Inflation Reduction Act of 2022, is expected to be taken up by the House of...more

Proskauer - Tax Talks

Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

Proskauer - Tax Talks on

On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Buchalter

Comments on Proposed 199A Regs Regarding Qualified REIT Dividends Due Soon

Buchalter on

Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more

Latham & Watkins LLP

Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

Latham & Watkins LLP on

The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability. Key Points: The base erosion and anti-abuse tax (BEAT) proposed regulations: ...more

Proskauer - Tax Talks

The Proposed BEAT Regulations

Proskauer - Tax Talks on

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Latham & Watkins LLP on

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Eversheds Sutherland (US) LLP

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

Lowndes

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Lowndes on

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Morrison & Foerster LLP

Treasury Expands Scope of REIT Spin-Off Rules in New Regulations

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more

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