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Controlled Foreign Corporations Tax Credits Internal Revenue Code (IRC)

Freeman Law

Tax Court Addresses a Difference in Dates in the TCJA

Freeman Law on

In Varian Medical Systems, Inc. v. Commissioner, the Tax Court addressed a seeming oversight in the Tax Cuts and Jobs Act of 2017 (the “TCJA”) involving the effective dates for amendments to section 78 and the enactment of...more

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

Eversheds Sutherland (US) LLP

It’s Not the Eggnog – New Jersey Proposes to Specially Allocate GILTI Based on GDP

On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

Jones Day

House of Representatives Releases First Draft of Tax Reform Bill

Jones Day on

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

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