News & Analysis as of

Treasury Regulations Proposed Regulation

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations for Transfer of Energy Credits under IRA

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

Freeman Law

Federal Income Tax Characterization of Transactions Involving Computer Programs

Freeman Law on

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

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR

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

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Emery on

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

Dechert LLP

New Proposed Tax Regulations on Replacing LIBOR with Other Variable Rates

Dechert LLP on

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

Wilson Sonsini Goodrich & Rosati

IRS Issues Proposed Regulations Classifying Cloud Transactions and Transfers of Digital Content for U.S. Federal Income Tax...

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

Holland & Hart LLP

Understanding the Child Care Contribution Tax Credit

Holland & Hart LLP on

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

Dechert LLP

Global Private Equity Newsletter - Fall 2015 Edition: Proposed Partnership Treasury Regulations – Consider the Guaranteed Payment

Dechert LLP on

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

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