News & Analysis as of

Revenue Procedures New Guidance Corporate Taxes

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

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

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

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

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 May 20 – May 24, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20 – May 24, 2019. May 20, 2019: The IRS issued a news release announcing the release of...more

McDermott Will & Emery

Weekly IRS Roundup May 13 – May 17, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13 – May 17, 2019. May 13, 2019: The IRS released a statement regarding the National...more

Dechert LLP

Part Cash, Part Stock, 100% Taxable – New IRS Guidance on RIC and REIT Distributions

Dechert LLP on

The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more

Morrison & Foerster LLP

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

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