Eric Sensenbrenner

Skadden, Arps, Slate, Meagher & Flom LLP

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Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

12/20/2023 / Foreign Tax Credits , Internal Revenue Code (IRC) , IRS , Partnerships , Pillar 2 , Relief Measures , Tax Credits , Taxation , U.S. Treasury

IRS Issues Notice on Payments Made in Exchange for State and Local Tax Credits

On May 23, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2018-54, stating that proposed regulations will be issued addressing the deductibility of certain payments made by taxpayers...more

5/29/2018 / IRS , Local Taxes , Qualified Charitable Distributions , State and Local Government , State Taxes , Tax Credits , Tax Cuts and Jobs Act , Tax Deductions , U.S. Treasury

"Proposed Treasury Regulations Dramatically Alter Existing Debt/Equity Law"

On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more

4/8/2016 / Corporate Structures , Debt , Equity Transactions , IRS , Proposed Regulation , REIT , U.S. Treasury

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