An Introduction to DAFs and Overview of the Newly Proposed DAF Regulations
Analyzing the Treasury's Illicit Finance Risk Assessment of Decentralized Finance - The Crypto Exchange Podcast
Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”
Torres Talks Trade podcast Episode 8 on Worker-Centered Trade
Kilptrick Townsend Digital Assets Minute | U.S. Treasury—Comments on Digital Assets Development Due August 8th
Stablecoin Regulation in an Unstable Time: The Fed and Treasury Address a Stablecoin Regulatory Framework
New Regulation: Statutes, Pillars, and the Build Back Better Act
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
#WorkforceWednesday: OSHA ETS in Review, Texas Vaccine Mandate Ban, Health Premium Incentives - Employment Law This Week®
Podcast: What's New for Insurers in Mental Health Parity Compliance - Diagnosing Health Care
Williams Mullen's COVID-19 Comeback Plan: Preparing Today for Tomorrow's PPP Audit
AF COVID-19 Podcast: PPP Loan Forgiveness - What Dealers Need to Know
Employment Law Now IV-62-Weekend Roundtable Discussion on Various Impacts of the Federal CARES/Coronavirus Programs
Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Qualified Opportunity Zone Fund Investments
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Podcast - Chamber of Commerce v. Internal Revenue Service
AML BSA and Sanctions Compliance Part II of II June 24, 2014
AML BSA and Sanctions Compliance I of II June 10 2014
Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more
On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more
On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more
On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...more
On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more
On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...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
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...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
In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more
Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more
On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more