This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more
Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more
The IRS and Treasury have issued proposed Treasury Regulations concerning the newly enacted Internal Revenue Code section 6418 which allows eligible taxpayers to sell most clean energy tax credits to unrelated third parties...more
The IRS and Treasury Department issued a new and finalized version of Treasury Regulation § 301.7602-1. The regulations took effect on September 7, 2021, and shine a new light on nongovernment contractors’ participation in...more
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more