News & Analysis as of

Depreciation Tax Cuts and Jobs Act Corporate Taxes

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Eversheds Sutherland (US) LLP

No surprises under the tree as IRS concludes no normalization violation in use of revised composite depreciation rate lives to...

On December 17, 2021, the IRS released Private Letter Ruling 202150003 where it concluded that a Taxpayer would not violate the normalization rules if it ratably amortized its Protected EDIT (defined below) pursuant to an...more

Eversheds Sutherland (US) LLP

IRS and Treasury issue final regulations on negative adjustments under UNICAP

On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes...more

Opportune LLP

Proposed Bonus Depreciation Regulations Favorable For Certain Energy Partnership Transactions

Opportune LLP on

President Trump signed into law the Tax Cuts and Jobs Act (the “TCJA”) on December 22, 2017. Included in the TCJA were amendments to IRC §168(k), which permits taxpayers to expense 100% of the costs of certain qualified...more

Eversheds Sutherland (US) LLP

The more things change the more things remain the same–temporary guidance regarding bonus depreciation rules under section 168(k)

Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

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• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Sheppard Mullin Richter & Hampton LLP

Real Estate Aspects of Tax Reform

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax laws will have a significant impact upon...more

Pillsbury Winthrop Shaw Pittman LLP

The Impact of the Tax Cuts and Jobs Act on LIHTC Investments

The Tax Cuts and Jobs Act contains changes impacting the LIHTC Program. While the low-income housing tax credit program emerged largely unscathed, the reduction in corporate tax rates will reduce equity pricing. ...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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