On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of...more
On September 21, 2020, the IRS and Treasury Department released the last set of final regulations (the 2020 Final Regulations) under the bonus depreciation rules of Section 168(k) of the Internal Revenue Code (the Code)....more
On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more
On April 10, 2020, the IRS and Treasury Department released Revenue Procedure 2020-22 (the Revenue Procedure), providing guidance with respect to the application of the provisions of the Coronavirus Aid, Relief, and Economic...more
On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more
In connection with the purchase and sale of the stock of a target corporation (a Corporate Target), the target often incurs various transaction costs (Transaction Costs) that may yield significant tax deductions (Transaction...more
6/28/2019
/ Acquisitions ,
Business Valuations ,
Complex Corporate Transactions ,
Corporate Taxes ,
Net Operating Losses ,
Purchase Agreement ,
Stock Sale Agreements ,
Target Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Transaction Costs
Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity,...more
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
10/18/2018
/ Business Taxes ,
Construction Industry ,
Energy Projects ,
Interim Rule ,
Investment Tax Credits ,
Investors ,
IRS ,
NAICS ,
Partnerships ,
Physical Work Test ,
Proposed Regulation ,
Protecting Americans from Tax Hikes (PATH) Act ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Reform ,
UBTI
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
9/20/2018
/ Anti-Avoidance ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Publicly-Traded Companies ,
REIT ,
SALT ,
Section 199 ,
Tax Cuts and Jobs Act ,
W-2
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
9/12/2018
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Energy Sector ,
International Tax Issues ,
IRS ,
MACRS ,
Property Tax ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
9/4/2018
/ Acquisitions ,
Arms Length Transactions ,
Bonus Depreciation ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
MACRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
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
8/31/2018
/ Acquisitions ,
Bonus Depreciation ,
Construction Industry ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
MACRS ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
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
5/3/2018
/ Audits ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Private Equity Funds ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
TEFRA
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
4/17/2018
/ Bi-Partison Balanced Budget Act (BBA) ,
Corporate Taxes ,
Energy Sector ,
FCC ,
FIRPTA ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
IRS ,
Like Kind Exchanges ,
Loss-Carryover ,
Net Operating Losses ,
New Rules ,
Opt-Outs ,
Partnership Agreements ,
Partnerships ,
Push-Out Requirements ,
Tax Audits ,
Tax Cuts and Jobs Act
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 (TCJA), with emphasis on how such developments impact the energy,...more
3/16/2018
/ Base Erosion Tax ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Energy Sector ,
GILTI tax ,
Holding Periods ,
International Tax Issues ,
Pass-Through Entities ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates
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 (TCJA), with emphasis on how such developments impact the energy,...more
3/1/2018
/ Audits ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
FIRPTA ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
TEFRA ,
Underpayment
The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more
2/16/2018
/ Base Erosion Tax ,
Corporate Taxes ,
Energy Sector ,
Holding Periods ,
International Tax Issues ,
IRS ,
Partnerships ,
REIT ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform