News & Analysis as of

Revenue Procedures New Guidance

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Proskauer - Tax Talks

Tax Court Provides Helpful Guidance on Requirements for Tax-Free Profits Interests

Proskauer - Tax Talks on

On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer’s receipt of interests in a partnership in exchange for services rendered to the sole owner of the...more

Eversheds Sutherland (US) LLP

A wolf in sheep’s clothing? IRS provides long-awaited capitalization guidance for natural gas companies

In recently issued Rev. Proc. 2023-15, the IRS provides a safe harbor method of accounting under which taxpayers may classify costs to repair, maintain, replace, or improve natural gas transmission and distribution property...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

Williams Mullen

IRS Issues New Guidance To Clarify and Provide Simplified Procedures for Resolving Certain Issues Related to S Corporation...

Williams Mullen on

The IRS recently issued Revenue Procedure 2022-19 (“Rev. Proc. 2022-19” or “the Revenue Procedure”), offering taxpayers clarification and new simplified procedures for resolving certain issues related to S corporation...more

McDermott Will & Emery

IRS Hints at Revenue Procedure 94-69 Update

McDermott Will & Emery on

At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more

Eversheds Sutherland (US) LLP

The Superfund Tax is back: Recent IRS guidance and background

As this nation prepared to celebrate the Independence Day long weekend, many were preparing for the July 1, 2022, reinstatement of the Superfund chemicals tax (the Superfund Tax). The Superfund Tax is an excise tax imposed on...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 23, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more

McDermott Will & Emery

Weekly IRS Roundup March 27 – April 2, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022... March 29, 2022: The IRS issued a news release reminding...more

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

Jones Day on

On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Guidance on Reporting of Tax-Exempt Income under PPP

The Internal Revenue Service issues three Revenue Procedures detailing how taxpayers can account for tax-exempt cancellation of indebtedness income arising from forgiven Paycheck Protection Program loans in their Federal tax...more

Morgan Lewis

IRS FAQs: A Potential Shield for Taxpayers—Not a Sword for the Service

Morgan Lewis on

The IRS recently issued guidance on the utility of and weight to be afforded informal “frequently asked questions” (FAQs) published on its website—clarifications that became necessary given the IRS’s heavy reliance on FAQs as...more

Bracewell LLP

Taxpayers Get Answers on 45Q Questions With IRS Guidance

Bracewell LLP on

The Internal Revenue Service released helpful guidance in Revenue Ruling 2021-13, regarding the scope of carbon capture equipment and the requirement that a taxpayer own the carbon capture equipment to qualify for carbon...more

Verrill

Revenue Procedure 2021-30: A New and (Further) Improved EPCRS

Verrill on

The Internal Revenue Service has updated the Employee Plans Compliance Resolution System (EPCRS) in several respects that will be helpful to retirement plan sponsors. Revenue Procedure 2021-30, published July 16, 2021,...more

Ballard Spahr LLP

IRS Releases Guidance on the Transition From LIBOR

Ballard Spahr LLP on

The IRS recently released helpful guidance in Revenue Procedure 2020-44 to assist the market’s transition from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (IBORs) to alternative reference...more

McDermott Will & Emery

Weekly IRS Roundup August 17 – August 21, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...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

Morgan Lewis

IRS Issues New Group Ruling Guidance in Proposed Form

Morgan Lewis on

The Internal Revenue Service (IRS) issued a proposed revenue procedure on group rulings that includes significant changes to the existing procedures under Rev. Proc. 80-27 and substantially restricts eligibility for group...more

Bracewell LLP

CARES Act Update: IRS Issues Guidance for Amending Partnership Tax Returns

Bracewell LLP on

On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more

Proskauer - Tax Talks

New Guidance Allows Publicly-Offered REITs and RICs to Issue up to 90% of Qualifying Dividends in the REIT or RIC’s Own Stock...

Proskauer - Tax Talks on

On May 4, 2020, the IRS issued Revenue Procedure 2020-19, which temporarily allows a publicly-offered REIT or RIC to pay as much as 90% of a distribution in its own stock (rather than cash or other property) and still have...more

Snell & Wilmer

IRS Issues Guidance for Stranded Travelers Impacted by COVID-19

Snell & Wilmer on

On April 9, we published an article, Global Tax Implications of COVID-19 on Stranded Cross-Border Workers and Multinational Companies, that discussed the analysis released by the Organization for Economic Cooperation and...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...

Foster Garvey PC on

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

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

Foley & Lardner LLP on

On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

Holland & Hart LLP

IRS Publishes Guidance on the Carbon Capture Tax Credit

Holland & Hart LLP on

On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Stoel Rives LLP

Coming Attractions: Section 45Q Carbon Sequestration Guidance, Part II

Stoel Rives LLP on

The IRS’s much anticipated new guidance for Section 45Q carbon sequestration tax credits was rather anticlimactic in that it focused on just two of the many issues for which the IRS had solicited comments in May 2019. Largely...more

44 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide