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Revenue Procedures Treasury Regulations

Kramer Levin Naftalis & Frankel LLP

IRS Denies Deductibility of Sell-Side Advisory Fees

In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more

Eversheds Sutherland (US) LLP

IRS issues new Section 45Q CCUS ruling

The IRS issued Revenue Ruling 2021-13 on July 1, 2021, which provides additional guidance regarding the section 45Q carbon capture, utilization and storage (CCUS) credit. More specifically, the ruling concludes that: ..A...more

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Emery on

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – 30, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019. August 26, 2019: The IRS released a Treasury Decision in which it issued...more

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