News & Analysis as of

Final Rules S-Corporation

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

Cozen O'Connor

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status

Cozen O'Connor on

The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations for Transfer of Energy Credits under IRA

The IRS and Treasury have issued proposed Treasury Regulations concerning the newly enacted Internal Revenue Code section 6418 which allows eligible taxpayers to sell most clean energy tax credits to unrelated third parties...more

Proskauer - Tax Talks

“Passthrough Deduction” Regulations Finalized

Proskauer - Tax Talks on

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Assisted And Senior Living Facilities

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Proskauer - Tax Talks

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

Proskauer - Tax Talks on

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

Proskauer Rose LLP

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

Sheppard Mullin Richter & Hampton LLP

Final Section 336(e) Regulations Allow Step-Up in Asset Tax Basis in Certain Stock Acquisitions

Final regulations were issued last month under IRC Section 336(e). These regulations present beneficial planning opportunities in certain circumstances....more

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