News & Analysis as of

Revenue Procedures Income Taxes Tax Cuts and Jobs Act

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 May 10 – May 14, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 10, 2021 – May 14, 2021... May 10, 2021: The IRS issued Revenue Procedure 2021-25,...more

Wyrick Robbins Yates & Ponton LLP

Final Like-Kind Exchange Regulations: What Is Real Property Anyway?

Just days before we all sat down to eat our Thanksgiving dinners, the Treasury Department gave us something else to digest:  final like-kind exchange regulations. These regulations define “real property” for purposes of Code...more

Eversheds Sutherland (US) LLP

“But wait, there’s more.” – Rev. Proc. 2020-39 provides guidance on the proper treatment of excess deferred taxes, and other...

On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more

Foster Garvey PC

A Taxpayer’s Ability to Use Net Operating Losses Was Significantly Restricted by the TCJA, but the CARES Act Temporarily Loosens...

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Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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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 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Whitman Legal Solutions, LLC

Revenue Procedure 2019-38 and the Rental Real Estate Safe Harbor under Section 199A

Self-employment creates additional challenges from an income tax perspective. Self-employed individuals must keep careful track of their business expenses so they can properly compute their income. For a professional...more

Proskauer - Tax Talks

Players, Staff and Draft Picks May be Traded Tax-Free Under New Safe Harbor

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On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for...more

McDermott Will & Emery

Weekly IRS Roundup February 11 – 15, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 11 – 15, 2019. February 11, 2019: The IRS issued a news release promoting online...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

McDermott Will & Emery

Weekly IRS Roundup January 14 – 18, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the...more

Eversheds Sutherland (US) LLP

Miracle on Constitution Avenue - IRS releases anticipated method change guidance regarding new income recognition standards under...

On November 29, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-60, which provides automatic accounting method change procedures for taxpayers seeking to comply with section 451(b), relating to the timing of...more

Proskauer - Tax Talks

New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs

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On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more

White and Williams LLP

Taxation of Carried Interests: 2017 Tax Act and Supplemental Guidance

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The ability of a partnership to grant service providers (typically key management) an interest in a partnership on a non-taxable basis, with potential long-term capital gain treatment on post-grant appreciation, is unique to...more

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