Ryan Carney

Ryan Carney

Vinson & Elkins LLP

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Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

9/20/2024  /  Alternative Minimum Tax , Depreciation , Foreign Corporations , Foreign Tax , Inflation Reduction Act (IRA) , IRS , Proposed Regulation , Tax Credits , U.S. Treasury

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more

6/19/2024  /  Arms Length Transactions , Economic Substance Doctrine , Financial Transactions , IRS , Master Limited Partnerships , Partnerships , Private Equity , Proposed Regulation , Related Parties , U.S. Treasury
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