On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more
On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more
On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulations regarding information reporting, determination of amount realized and basis, and backup...more
On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more
The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more
1/5/2023
/ Biden Administration ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
On November 18, 2022, the Internal Revenue Service (IRS) published private letter ruling 202246008 (the PLR), which concluded that a transaction qualifies as a tax-free spin-off under Section 3552 despite the fact that the...more
On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more
Last week, the Internal Revenue Service (IRS) issued additional guidance on two outstanding issues regarding Paycheck Protection Program (PPP) Loans and the Employee Retention Tax Credit (ERTC) provisions of the Coronavirus...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) enacted several key measures intended to provide tax and financial relief to businesses navigating the COVID-19 crisis. Those measures included the Employee...more
The U.S. Congress, the U.S. Internal Revenue Service (IRS) and the Treasury Department are continuing to respond to the economic disruption caused by the Novel Coronavirus (COVID-19) with measures intended to provide relief...more
On February 28, 2020, the Internal Revenue Service (IRS) released private letter ruling 202009002 (the PLR), which concluded that an absence of income does not, under the facts of the PLR, prevent a line of business from...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more
9/6/2019
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Earned Income ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more
On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more
On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more
On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more
4/22/2016
/ Conversion ,
Convertible Debt ,
Corporate Issuers ,
Dividends ,
Foreign Persons ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Shareholder Distributions ,
Shareholders ,
Stocks ,
U.S. Treasury ,
Withholding Requirements