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
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
The U.S. Department of the Treasury and IRS recently issued guidance aimed at curtailing purportedly abusive basis-shifting transactions utilized by businesses taxed as partnerships. This guidance represents additional...more
On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more
Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more
On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more
The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more
The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more
On March 5, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment election of the advanced manufacturing investment credit...more
In holding that that Treas. Reg. § 1.170A-14(g)(6)(ii) (Proceeds Regulation) is procedurally invalid under the Administrative Procedure Act (APA), the U.S. Tax Court abandoned its precedent in Oakbrook Land Holdings, LLC v....more
The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the production of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more
Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
The final regulations are effective on May 10, 2024. Last week, the Department of the Treasury issued final regulations that address the Elective Pay program (also called direct pay), predominantly under Internal Revenue...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more
Starting in 2024, many entities that are created in or registered to do business in the United States will be required to file BOI reports with FinCEN. With the effective date fast approaching, criticism surrounding...more
New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules. The IRS has formally given notice that it intends to...more
The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more
Family offices routinely create, manage, and invest in multiple entities, including corporations, limited liability companies, and partnerships. For entities formed or operating in the United States, there has never been a...more
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more
Increasing demand for transparency and tax rules focused on the ownership of foreign financial accounts and interests in foreign trusts and entities affect private wealth planning. There are steps you can take to comply with...more
More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering...more