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 sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more
On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to taxpayers with respect to the widely reported...more
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
On October 9, 2019, the U.S. Department of the Treasury and the Internal Revenue Service proposed regulations (“Proposed Regulations”) addressing the transition from London interbank offered rate (“LIBOR”) to the use of...more
On August 9, 2019, the U.S. Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (the proposed regulations) that would classify cloud transactions for U.S. federal income tax...more
The Child Care Contribution Tax Credit (the “CCTC”) provides a valuable tax credit against a taxpayer’s Colorado state income tax. The credit equals 50% of the amount of a contribution made to a qualifying Colorado charitable...more
Proposed regulations were issued under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), that address circumstances when certain arrangements between partnerships and their partners will be...more