News & Analysis as of

U.S. Treasury Tax Code

Bricker Graydon LLP

The Possible Repeal of the Tax Exemption of Municipal Bond Interest

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You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.”  This issue...more

Foley Hoag LLP - Energy & Climate Counsel

IRS Issues Guidance and Requests Comment on Provisional Emission Rate Process for Hydrogen Tax Credit

On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...more

Rivkin Radler LLP

Grantor Trusts On The Precipice?

Rivkin Radler LLP on

Where Are We? Have you seen the Triumvirate of late? No, not Julius, Pompey, and Crassus. I’m referring to more contemporary political figures, whose names and exploits are not likely to appear in volumes that will be...more

McDermott Will & Emery

IRS Reasserts That Forgivable PPP Expenses Are Not Deductible, but Is Legislative Relief on the Way?

McDermott Will & Emery on

Loans under the Payroll Protection Program (PPP) are eligible for forgiveness depending upon whether and when the loan proceeds are used for qualified business expenses. One of the benefits of this program is that there is no...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

Bracewell LLP on

The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

McDermott Will & Emery

Weekly IRS Roundup September 2 – 6, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – 23, 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 August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

McDermott Will & Emery

Proposed BEAT Regulations | Tax-Free Transactions May Give Rise to a Liability

McDermott Will & Emery on

On December 13, 2018, US Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations for the Base Erosion and Anti-Abuse Tax (the BEAT), which was added to the Code as part of the 2017 Tax...more

Fenwick & West LLP

US Taxation of IP After Tax Reform

Fenwick & West LLP on

Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more

Fenwick & West LLP

Intellectual Property Bulletin - Summer 2018

Fenwick & West LLP on

In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

Holland & Knight LLP

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

Holland & Knight LLP on

Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

Akin Gump Strauss Hauer & Feld LLP

What’s New in Washington - November 2017

Congress continues its heavy workload with the Thanksgiving recess roughly three weeks away. On October 26, the House passed the Senate’s Fiscal Year 2018 budget resolution by the slim margin of 216-212—opening the door for...more

Bryan Cave Leighton Paisner

Treasury Green Book Proposals — Definition of Executor

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

King & Spalding

Could 2016 Be the Year When Congress Finally Addresses Tax Reform?

King & Spalding on

Like Vladimir and Estragon waiting for Godot, Washington has been waiting for Congress to tackle tax reform. The reason for the lack of action is a fundamental disagreement between Democrats and Republicans over what reform...more

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