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Recent Release of Updated Procedures for Section 355 Private Letter Rulings

The US Department of the Treasury (Treasury Department) and the IRS recently released Revenue Procedure 2024-24 (Revenue Procedure) and Notice 2024-38 (Notice) establishing revised standards and procedures for taxpayers...more

Transitional Tax Reporting Guidance for Business Transactions Involving Digital Assets

In Announcement 2024-4, the IRS and the US Department of the Treasury stated that, until regulations are issued, taxpayers will not be required to treat digital assets received in the course of their trade or business as cash...more

Treasury Department Issues Proposed Regulations for Brokers of ‘Digital Assets’

On August 25, 2023, the US Department of the Treasury issued proposed regulations that would impose new information reporting requirements for brokers that facilitate certain transactions involving “digital assets” – if...more

IRS Announces Transition Guidance for Stock Buyback Excise Tax

The Inflation Reduction Act of 2022 added Internal Revenue Code Section 4501, which imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations effected after December 31, 2022. As described in...more

Alert: Treasury Department Issues Proposed Rules on Cloud Transactions, Other Digital Content

On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of “cloud transactions” and certain other transactions involving digital content (the “Proposed Regulations”)....more

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