News & Analysis as of October 12, 2024

Anti-Abuse Rule

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on 5/6/2024

Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

Treasury Department and IRS Release Long-Awaited Guidance on Credit Transfers

Bracewell LLP on 6/23/2023

On June 14, 2023, the Treasury Department and the Internal Revenue Service (IRS) released long-awaited guidance (the Credit Transfer Guidance) regarding the transfer of energy transition tax credits under Section 6418, which...more

IRS Signals Increased Reliance on Partnership Anti-Abuse Rules

Husch Blackwell LLP on 4/28/2023

Speaking at a Practicing Law Institute program on April 25, Internal Revenue Service (IRS) lawyer Clifford Warren indicated that the IRS has been using the anti-abuse rule of Treasury Regulation Section 1.701-2 to scrutinize...more

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on 1/15/2020

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on 12/27/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Emery on 12/18/2019

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on 6/13/2019

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more

Treasury Provides Additional Guidance on Opportunity Zone Provisions

McDermott Will & Emery on 5/3/2019

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Additional Proposed Regulations Issued Regarding Opportunity Zones

Katten Muchin Rosenman LLP on 4/24/2019

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on 4/24/2019

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

Proskauer - Tax Talks on 1/28/2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

Proskauer - Tax Talks on 12/6/2018

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

Tax Alert: Understanding the New Pass-Through Business Deduction Rules Under Code Section 199A

Verrill on 8/28/2018

Due to the significant changes to the Internal Revenue Code (“Code”) made by the Tax Cuts and Jobs Act (“Tax Act”) at the end of last year, the Department of the Treasury has been very busy issuing guidance and proposed...more

Newly Proposed IRS Regulations Put a Monkey Wrench in Plans by Service Businesses Seeking IRC § 199A Deduction

Foster Garvey PC on 8/9/2018

The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more

IRS Proposes Modifications to Proposed Income Inclusion Regulations under Section 409A

Proskauer - Tax Talks on 7/18/2016

In general, proposed rulemaking issued in December 2008 with respect to income inclusion under Section 409A of the Internal Revenue Code of 1986, as amended (available here) provides that if there is a Section 409A violation...more

IRS Releases Proposed Regulations To Clarify Section 409A Provisions

Proskauer - Tax Talks on 7/14/2016

The Internal Revenue Service (IRS) recently issued proposed Treasury Regulations that would clarify certain provisions of the final regulations under Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”)....more

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