These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more
On January 13, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-112261-23 and REG-112261-24) adding and amending parts of the regulations...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021. U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes - The global tax landscape is...more
Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on existing law cannot be revoked if later regulatory changes...more