News & Analysis as of October 12, 2024

Income Taxes › Internal Revenue Service › Proposed Rules

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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... more +

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 -

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Eversheds Sutherland (US) LLP on 9/6/2024

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Cadwalader, Wickersham & Taft LLP on 10/25/2023

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry. By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Proposed Rule Has Serious Implications on the Taxation of Fixed Indemnity and Other Similar Coverages

Groom Law Group, Chartered on 7/13/2023

On July 7, the Departments of Labor, Treasury, and Health and Human Services published a proposed rule (“Proposed Rule”) regarding, among other things, the requirements for fixed and hospital indemnity insurance to be...more

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on 6/14/2022

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Bradley Arant Boult Cummings LLP on 9/7/2021

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

Six Takeaways: Utilization and Structuring For Section 45Q Carbon Capture Credits

McDermott Will & Emery on 6/16/2020

The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more

[Webinar] Utilization and Structuring For Section 45Q Carbon Capture Credits - June 11th, 12:30 pm EST

McDermott Will & Emery on 6/9/2020

The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

Snell & Wilmer on 2/21/2020

The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

Weekly IRS Roundup September 2 – 6, 2019

McDermott Will & Emery on 9/9/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

Nine Estate Planning Tips to Prepare for 2019

Pillsbury Winthrop Shaw Pittman LLP on 12/21/2018

There have been a number of significant estate planning developments in 2018 which will help clients prepare for 2019. The historically high increased exemption amounts for gift, estate and generation-skipping transfer...more

Investing In Qualified Opportunity Funds

Brooks Pierce on 11/8/2018

The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more

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