News & Analysis as of

Tax Reform Proposed Regulation

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Gray Reed

IRS Further Combats Basket Contract Transactions with Proposed Regs

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The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

McDermott Will & Emery

Weekly IRS Roundup May 20 – May 24, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

Cadwalader, Wickersham & Taft LLP

Proposed Regulations for Buyback Tax Hit LBOs, Preferred Stock but Spare Tier 1 Capital

The government released proposed regulations this month implementing the excise tax imposed on repurchases of corporate stock that was enacted in 2022.  Although these regulations provide some welcome clarity as to the scope...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

McDermott Will & Emery

Weekly IRS Roundup April 1 – April 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

McDermott Will & Emery

Weekly IRS Roundup February 19 – February 23, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 19, 2024 – February 23, 2024. February 20, 2024: The IRS published Announcement 2024-12, which...more

Holland & Knight LLP

Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?

Holland & Knight LLP on

En este episodio de "A Lo Legal En Par Minutos", nuestro abogado Edwin Cortés conversa con Gustavo Pardo, socio del área tributaria, sobre el impacto de la reforma tributaria de 2022 en Colombia. Nuestros abogados abordan...more

McDermott Will & Emery

Weekly IRS Roundup January 15 – January 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024. ...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

McDermott Will & Emery

Weekly IRS Roundup December 25 – December 29, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 25, 2023 – December 29, 2023...more

McDermott Will & Emery

New York Formally Adopts Corporate Tax Reform Regulations

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On December 27, 2023, the New York State Department of Taxation and Finance (Department) adopted corporate tax reform regulations addressing New York’s corporate tax reform effective in 2015. The adopted regulations are...more

McDermott Will & Emery

Weekly IRS Roundup November 20 – November 24, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 20, 2023 – November 24, 2023....more

Cadwalader, Wickersham & Taft LLP

Treasury's Recycling Bin Overflows with Comments to Their Proposed Rules on Energy Tax Credit Transfers

On June 14, 2023, the IRS requested comments on their proposed regulations on the transferability provisions created under the Inflation Reduction Act of 2022 (the “IRA”) that allow developers to sell clean energy tax...more

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

McDermott Will & Emery

Weekly IRS Roundup August 14 – August 18, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 14, 2023 – August 18, 2023...more

Eversheds Sutherland (US) LLP

New York moves to finalize corporate franchise tax regulations

On August 9, 2023, the New York State Department of Taxation and Finance (Department) submitted its draft corporate franchise tax regulations for publication in the State Register – a significant and necessary step in the...more

McDermott Will & Emery

Weekly IRS Roundup July 31 – August 4, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 31, 2023 – August 4, 2023....more

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

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Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

McDermott Will & Emery

Weekly IRS Roundup April 24 – April 28, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 – April 28, 2023...more

Freeman Law

IRS Issues Proposed Regulations under Section 6751(b)

Freeman Law on

When is Written Managerial Approval Required? In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the “Act”).  Buried within...more

Mayer Brown

US Treasury to Propose Regulations on Energy Community Bonus Adders

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On April 4, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on qualifying for the energy community bonus credit under Sections...more

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