News & Analysis as of

Tax Reform Safe Harbors

A&O Shearman

Navigating the new elective safe harbor for the Domestic Content Bonus Tax Credit

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The U.S. Treasury Department and the Internal Revenue Service have issued a new safe harbor that will make it easier for U.S. solar, onshore wind and battery storage projects with U.S.-sourced components to qualify for...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Eversheds Sutherland (US) LLP

They have arrived: New York issues “final draft” corporate income tax apportionment regulations

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more

McDermott Will & Emery

Weekly IRS Roundup January 11 – January 15, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 11, 2021 – January 15, 2021... January 11, 2021: The IRS released TD 9948 containing...more

Katten Muchin Rosenman LLP

Structured Finance Year in Review and the Outlook for 2021 | Key Takeaways

On December 8 and 10, Katten’s Structured Finance and Securitization Department presented the “Year in Review and Outlook for 2021” webinar series. Topics covered by Katten attorneys and guest speakers include the impact of...more

McDermott Will & Emery

Weekly IRS Roundup December 7 – December 11, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 7 – December 11, 2020... December 7, 2020: The IRS released TD 9937 related to...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - February 2020

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more

Troutman Pepper

The SECURE Act Brings Significant Changes for Retirement Plans and IRAs

Troutman Pepper on

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act), signed into law on Dec. 20, 2019, will have a wide-ranging impact on tax-qualified retirement plans and individual retirement accounts,...more

Ballard Spahr LLP

SECURE Act In; Cadillac Tax Out: The Spending Act Makes Serious Changes to Benefits Rules

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Below is a summary of those key provisions. I. SECURE Act The Setting Every Community Up for Retirement Enhancement Act of 2019 (the SECURE Act, H.R. 1994) is arguably the most significant and comprehensive retirement saving...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

Williams Mullen on

As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

Sands Anderson PC

Tax Reform: Section 199A Qualified Business Income Deduction – Safe Harbor for Rental Real Estate Businesses

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The Internal Revenue Code (“IRC”) Section 199A Qualified Business Income Deduction (“QBI Deduction”) generally provides a 20% deduction (or reduction) of a taxpayer’s qualified net business income received from a pass-through...more

Cadwalader, Wickersham & Taft LLP

Treasury Issues Proposed Regulations on Opportunity Zones

On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage

• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more

Dickinson Wright

Employers Need to Update their Model IRS Rollover Notices after IRS Changes

Dickinson Wright on

The IRS has updated its “safe harbor explanations” for eligible rollover distributions to reflect recent statutory changes and IRS guidance. Employers should review this latest guidance and update their explanations...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - September 24, 2018

TAX TIDBIT - With the midterm elections just weeks away, both parties have been hitting the campaign trail hard, strutting their stuff to win over voters. ...more

King & Spalding

Compensation and Benefits Insights - September 2018

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The IRS recently updated its two model safe harbor explanations that can be used to satisfy the requirement under Section 402(f) to provide notices setting forth certain information to participants who are eligible for...more

Holland & Knight LLP

Six Tips for Tribal Governments to Reduce Tribal Member Taxes in 2018

Holland & Knight LLP on

• President Donald Trump on Dec. 22, 2017, signed the Tax Cuts and Jobs Act, the first major overhaul of the U.S. tax system in over 30 years. • Although few of the enacted provisions are specific to Indian Country, several...more

Fisher Phillips

Could Congress Soon Swoop In To Aid The Gig Economy?

Fisher Phillips on

Reports out of Washington, D.C. indicate that gig economy businesses could be in for an end-of-the-year treat in the form of game-changing legislation. Chris Opfer and Tyrone Richardson of Bloomberg BNA report that Senate...more

Foley & Lardner LLP

The GOP’s Tax Cuts and Jobs Act Includes Changes Impacting the Renewable Energy Industry

Foley & Lardner LLP on

On November 3rd, House Ways and Means Committee Chairman Kevin Brady (R. Tex.) released the “chairman’s mark” to H.R. 1, the “Tax Cuts and Jobs Act” (TCJA). The TCJA represents the most extensive rewrite of the Internal...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 2

Editor's Note - Welcome to Tax Talk 9.02. By this fall, we may look back on Q2 2016 with some nostalgia. Of course, there is the U.S. presidential election on November 8th, but U.S. tax advisors right now are more...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 2

State Tax Department Releases New Draft Article 9-A Combined Reporting Regulations - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax...more

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