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Internal Revenue Service Financing

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Mayer Brown

The Inflation Reduction Act as a Mining Finance Alternative

Mayer Brown on

It has been a little over a year and a half since the enactment of the Inflation Reduction Act (“IRA”) promoted by the Biden Administration, and critical mineral producers and their investors are rushing to find ways to...more

Holland & Knight LLP

IRS Updates and Modernizes Rules Governing Utility Securitizations

Holland & Knight LLP on

Since the issuance of Revenue Procedure (Rev. Proc.) 2005-62, many utilities have used securitizations authorized by state law to secure collections of stranded costs upon the retirement of certain generation plants or costs...more

DarrowEverett LLP

1031 Exchanges and the Complexities of Seller Financing

DarrowEverett LLP on

With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s...more

Perkins Coie

Blockchain Week in Review - May 2020 #3

Perkins Coie on

US Developments - Federal and State Regulatory Developments - OCC Announces a New Acting Comptroller of the Currency - On May 21, 2020, current Comptroller of the Currency Joseph M. Otting announced that he is stepping...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Orrick, Herrington & Sutcliffe LLP

IRS Focuses on Tax Exempt Financings Involving Developers

For a number of years, the IRS Office of Tax-Exempt Bonds ("TEB") has expressed concerns about potential tax abuses that may exist in what it has characterized as "developer-driven deals" involving the use of tax-exempt...more

Proskauer - Not for Profit/Exempt...

New Flexibility for Joint Ventures Using Tax-Exempt Bond-Financed Property

On October 26, 2015, the IRS released final regulations under Sections 141 and 145 of the Internal Revenue Code concerning the use of property financed with tax-exempt bond proceeds. The bulk of the new regulations fill a...more

Mintz

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

Mintz on

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

McNees Wallace & Nurick LLC

Five Things To Know When Contemplating the Issuance of Municipal Debt

Municipal financings are often perceived as a very complex, and even overwhelming, undertaking. The various rules and regulations which govern the process oftentimes seem complicated and difficult to understand. Keep in mind...more

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