On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more
IRS LB&I has updated several pieces of administrative guidance, including a notice regarding the transition period for complying with increased substantiation requirements for research credit refund claims and two practice...more
On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more
Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes -
On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more
On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more
On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more
On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more
In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more
At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more
On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more
The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more
9/12/2023
/ Capital Expenditures ,
Interim Guidance ,
IRS ,
Proposed Regulation ,
Research and Development ,
Revenue Procedures ,
Software ,
Software Developers ,
Tax Cuts and Jobs Act ,
Technology Sector ,
U.S. Treasury
In an opinion released July 27, 2023, the Third Circuit affirmed a 2021 Tax Court decision upholding a pharmaceutical company’s immediate deduction of patent defense litigation costs in suits brought under the Hatch-Waxman...more
8/1/2023
/ Abbreviated New Drug Application (ANDA) ,
Food and Drug Administration (FDA) ,
Hatch-Waxman ,
IRS ,
Mylan Pharmaceuticals ,
Patent Infringement ,
Patent Litigation ,
Patents ,
Pharmaceutical Industry ,
Pharmaceutical Patents ,
Tax Court ,
Tax Deductions