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Domestic Corporations U.S. Treasury

Dechert LLP

Stock Repurchase Excise Tax Regulations Finalized: Effect on RICs

Dechert LLP on

On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more

Eversheds Sutherland (US) LLP

Final regulations address domestically controlled qualified investment entities

On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more

Goodwin

IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

Goodwin on

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

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On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Issue Proposed Regulations Regarding the Stock Buyback Excise Tax

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

Katten Muchin Rosenman LLP

Action Required: Corporate Transparency Act Reporting Is Here

This advisory provides a general summary of the Corporate Transparency Act and its requirements and is not intended to, and does not, provide legal, compliance or other advice to any individual or entity....more

Hahn Loeser & Parks LLP

Business Owners to Face New Federal Reporting Obligations Under the Corporate Transparency Act in 2024

As we approach the end of 2023, nearly all privately owned businesses operating in the United States must prepare for the implementation of the Corporate Transparency Act (“CTA”), a federal law taking effect on January 1,...more

A&O Shearman

Inflation Reduction Act: New Guidance on Domestic Content Bonus Credits

A&O Shearman on

On May 12, 2023, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2023-38 (the “Notice”) to provide guidance on the domestic content requirements under IRC sections 45, 45Y,...more

Vinson & Elkins LLP

Highly Anticipated Domestic Content Bonus Guidance Released

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On May 12, 2023, the Department of the Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) issued Notice 2023-38 (the “Notice”), providing guidance on the rules taxpayers must satisfy to qualify for the...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

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The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Release Interim Guidance on the One-Percent Excise Tax on Stock Repurchases by Publicly Traded Companies

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

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Corporate Transparency Act Requirement

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more

BakerHostetler

FinCEN Requires Wide Array of Companies To Report Beneficial Ownership Information To Strengthen Transparency of US Financial...

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On September 29, 2022, FinCEN issued a final rule requiring most corporations, limited liability companies and other entities created in or registered to do business in the United States to report information regarding their...more

Dorsey & Whitney LLP

Inflation Reduction Act: New U.S. Excise Tax on Stock Repurchase Transactions Applicable to Certain Canadian Companies

Dorsey & Whitney LLP on

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more

Dorsey & Whitney LLP

Inflation Reduction Act: New Excise Tax Discourages Stock Repurchase Transactions

Dorsey & Whitney LLP on

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by...more

McDermott Will & Emery

Government Releases Final Regulations on FDII and GILTI Deduction

McDermott Will & Emery on

On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more

Society of Corporate Compliance and Ethics...

Trump administration rejects pleas to lower tariffs

Report on Supply Chain Compliance 3, no. 7 (April 2020) A letter signed by more than 100 companies pleading for relief from tariffs has fallen on deaf ears. The group that sent the letter, Americans for Free Trade, cites...more

McDermott Will & Emery

Weekly IRS Roundup February 10 – 14, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Proskauer Rose LLP

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Moore & Van Allen PLLC

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

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Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

Katten Muchin Rosenman LLP

New Proposed Rules Limit the Negative Tax Consequences of Section 956 "Deemed Dividends" - Certain Foreign Guarantees and Stock...

On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more

Holland & Knight LLP

Tax Reform's New Incentives for Investments in Low-Income Communities: Part 2

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• Part 1 of this series of Holland & Knight alerts described a new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." Part 1 also explained the...more

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