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U.S. Treasury Private Letter Rulings

Holland & Knight LLP

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

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Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

Skadden, Arps, Slate, Meagher & Flom LLP

New IRS Ruling Guidelines Significantly Impact Tax-Free Spin-Offs

On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more

Holland & Knight LLP

Eyes on Energy Tax Update: First Quarter 2023

Holland & Knight LLP on

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more

Holland & Knight LLP

Eyes on Energy Tax Update: January 2023

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Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The fourth quarter of 2022 brought a flurry of energy tax...more

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

Freeman Law on

Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

McDermott Will & Emery

Weekly IRS Roundup December 28, 2020 – January 8, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021... December 29, 2020: The IRS released Revenue Procedure...more

McDermott Will & Emery

Weekly IRS Roundup November 25 – 29, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 25 – 29, 2019. November 26, 2019: The IRS issued a News Release regarding a Revenue...more

McDermott Will & Emery

Weekly IRS Roundup October 28 – November 1, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019. October 30, 2019: The IRS issued an Action on Decision in which...more

McDermott Will & Emery

Weekly IRS Roundup October 21 – 25, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 21 – 25, 2019. October 21, 2019: The IRS issued a news release in which it announced the...more

McDermott Will & Emery

Weekly IRS Roundup June 17 – 21, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17 – 21, 2019. June 18, 2019: The IRS issued a news release noting that it and the US...more

Wilson Sonsini Goodrich & Rosati

IRS Ruling May Signal Relaxation of "Collection of Income" Prong of Section 355 Active Trade or Business Test

On May 17, 2019, the Internal Revenue Service (IRS) published private letter ruling 201920008 (the PLR), which concluded that a transaction qualifies as a tax-free spin-off under Section 355 despite the fact that the...more

BCLP

IRS Takes Step Towards De-Risking Retiree Lump Sum Windows

BCLP on

On March 6, 2019, the IRS announced that it will not amend the minimum required distribution regulations under Code section 401(a)(9) to expressly prohibit lump-sum window elections for retirees who are already receiving...more

Proskauer - Employee Benefits & Executive...

IRS Reopens Opportunity to Cash Out Retirees in Pay Status—At Least For Now

One de-risking tool for employers with defined benefit pension liabilities is to allow participants to receive lump-sum distributions. Although lump sums result in a short-term cash drain, they reduce the plan’s long-term...more

Poyner Spruill LLP

IRS Announces Retiree Lump-Sum Windows Are Back On The Table

Poyner Spruill LLP on

Pension plan sponsors have been looking for opportunities to manage their growing pension liabilities for many years now. In 2015, the Internal Revenue Service (IRS) closed the door on sponsors who were considering offering...more

Bracewell LLP

Bracewell Tax Report - January 2019

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Proskauer Rose LLP

Wealth Management Update - December 2018

Proskauer Rose LLP on

December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - Important federal interest rates continue to rise. The December applicable federal rate...more

Proskauer - Tax Talks

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

Mintz - Public Finance Viewpoints

Tax Guidance to Slow Under Trump. Even More Emphasis on Letter Rulings in Bond Transactions?

As the Trump administration attempts to substantially reduce the amount of federal regulations, both the Deputy Tax Legislative Counsel of the Treasury Department and an Associate Chief Counsel at the Internal Revenue Service...more

Coblentz Patch Duffy & Bass

Private Ruling Exempts Property Management Services from Self-Dealing

A new private ruling may be of great interest to clients with substantial real estate interests who wish to contribute one or more properties to a family foundation. The ruling suggests that payment by the foundation to a...more

McDermott Will & Emery

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

McDermott Will & Emery on

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

Morrison & Foerster LLP

Final Regulations Clarify the Definition of “Real Property” Under the REIT Rules

On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more

Latham & Watkins LLP

Treasury Department Issues Final Regulations on Real Property Definition for REIT Purposes

Latham & Watkins LLP on

Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules. On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more

Seyfarth Shaw LLP

Program Related Investments: Final Regulations

Seyfarth Shaw LLP on

Final Regulations Highlight the Broad Range of Available PRI Purposes, Recipients and Financial Structures - Final program related investment (PRI) regulations released and effective on April 25, 2016 illustrate the...more

Latham & Watkins LLP

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

Latham & Watkins LLP on

IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing. “I’m mad as Hell, and, frankly, I’m not going to take it anymore.” — Paraphrase of concerned citizen and...more

McDermott Will & Emery

Recent IRS Guidance Prohibits Lump-Sum Windows for Pension Retirees, Updates Pension Mortality Tables for 2016

The Internal Revenue Service (IRS) recently issued two significant notices for employers that sponsor defined benefit pension plans, particularly those considering lump-sum windows as a “de-risking” option for their plans....more

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