On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more
2/22/2021
/ Corporate Fines ,
Corporate Taxes ,
Final Rules ,
IRS ,
Restitution ,
Section 162(f) ,
Section 6050X ,
Settlement ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more
5/29/2020
/ Civil Monetary Penalty ,
Corporate Fines ,
Corporate Taxes ,
Enforcement Actions ,
IRS ,
Public Comment ,
Remediation ,
Restitution ,
Section 162(f) ,
Section 6050X ,
Settlement ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
A corporation may not deduct previously capitalized costs that facilitated an initial public offering (IPO) even when it later ceases to be a publicly traded company, according to an internal memorandum by the Internal...more
5/28/2020
/ Capitalization ,
Corporate Taxes ,
Going-Private Transactions ,
Initial Public Offering (IPO) ,
IRS ,
Memorandum Opinions ,
Popular ,
Publicly-Traded Companies ,
Stock Issuance ,
Takeovers ,
Tax Code ,
Tax Deductions
A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more
The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus depreciation regime may work in the context of many common acquisitions involving...more