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Nelson Mullins Tax Report – Proposed Regulations on Information Reporting for Digital Asset Sales and Exchanges

On August 29, 2023, the Internal Revenue Service (IRS) issued new proposed regulations regarding reporting obligations for parties engaged in certain digital transactions.  The proposed regulations address the reporting...more

Treasury and IRS Release Guidance on Advanced Energy Project Credits, Direct Payment, and Transferability of Investment Tax...

The Treasury Department and Internal Revenue Service (IRS) have released Notice 2023-44 and proposed regulations to provide long-anticipated guidance on the application procedures for the Section 48C(e) credit and for the...more

New Qualified Opportunity Zones Guidance: Proposed Regulations and Revenue Ruling 2018-29

The United States Treasury Department (“Treasury”) issued proposed regulations (Prop. Reg. §1.1400Z-2) (the “Proposed Regulations”) on October 19, 2018, under Section 1400Z-2 of the Internal Revenue Code, as amended, (the...more

Treasury Releases Initial Guidance Regarding Opportunity Zone Investments

The IRS and Treasury Department released their first set of proposed regulations on October 19, 2018, to clarify and provide guidance regarding the implementation of the Qualified Opportunity Zone program contained in the Tax...more

New Revenue Procedure Clarifies Treatment of Income from Foreign Subsidiaries of U.S. REIT’s

The Internal Revenue Service (the “IRS”) released Revenue Procedure 2018-43 (“Rev. Proc. 2018-43”) in mid-September regarding the treatment of certain items of income from foreign subsidiaries of real estate investment trusts...more

Proposed Regulations Provide Guidance on 20% Deduction for Qualified Business Income

The Department of Treasury issued in August proposed regulations (REG-107892-18) (the “Proposed Regulations”) under Section 199A of the Internal Revenue Code, providing individual taxpayers with interests in certain...more

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