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Internal Revenue Service Proposed Rules

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.  
Eversheds Sutherland (US) LLP

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

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

Holland & Hart LLP

the buzz: Cannabis News & Policy Update - July 2024

Holland & Hart LLP on

Welcome to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. - This month's highlights include: ...more

Cadwalader, Wickersham & Taft LLP

Everything You Need to Know About Energy Tax Credit Sales

The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits.  ...more

Foodman CPAs & Advisors

1099-DA Could Come 2025

On 4/19/24, the IRS published draft Form 1099-DA for reporting digital asset proceeds from broker transactions. The IRS states that: “This early draft release reflects the notice of proposed rulemaking that appeared in the...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Proposed Rules on New Tech-Neutral Clean Energy PTC and ITC

On May 29, 2024, the Internal Revenue Service (IRS) and the Department of Treasury issued proposed regulations (REG-119283-23) addressing the new technology neutral clean electricity production tax credit (PTC) in section 45Y...more

Perkins Coie

IRS Clean Vehicle Tax Credit Rule Adds Hurdles for Domestic Electric Vehicle Manufacturing

Perkins Coie on

The Internal Revenue Service (IRS) published a final rule on May 6, 2024, defining eligibility requirements for the clean vehicle credit under Section 30D of the Internal Revenue Code, enacted by the Inflation Reduction Act...more

McDermott Will & Emery

How Pending Fishing Boat Cases at the Supreme Court Could Rock the Benefits Plan Boat

McDermott Will & Emery on

Thanks to two cases about federally mandated observers on fishing boats, judicial deference to agencies is likely to soon get weaker – and more unpredictable – with wide-ranging impacts for employee benefits. Less deference...more

Roetzel & Andress

IRS Issues Proposed Regulations on Long-Term, Part-Time Employees

Roetzel & Andress on

Historically, qualified retirement plans have excluded part-time employees from participation. An employer’s ability to do so has now been limited by the Setting Every Community Up for Retirement Enhancement Act (“SECURE...more

Seyfarth Shaw LLP

The Long Wait for the Long-Term Part-Time Guidance is Over

Seyfarth Shaw LLP on

Seyfarth Synopsis: It’s here for your post-Thanksgiving turkey hangover reading pleasure! The Department of Treasury and IRS released on Friday (in the middle of most people’s long holiday weekend) their proposed rules for...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - November 2023

The November Monthly Minute digs into the new proposed LTPT regulations, 2024 benefit limits, and the NBA health plan fraud verdict. Indigestion from Turkey and Stuffing or the IRS’ Proposed LTPT Regulations? ...more

Husch Blackwell LLP

Notice of Proposed Rulemaking – ITC and Qualified Biogas Property

Husch Blackwell LLP on

On November 17, 2023, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (the “NPRM”) with respect to Proposed Regulations under section 48 of the Internal Revenue Code of 1986 (the “Code”). The NPRM...more

Dechert LLP

ERISA Déjà-Boo? New Halloween Fiduciary Proposal May Be a Real Scream

Dechert LLP on

The Department of Labor (“DOL”) on October 31, 2023—Halloween—issued a release (the “Release”) proposing to make changes to the 1975 rule (the “1975 Rule”) defining when institutions and individuals are providing fiduciary...more

Amundsen Davis LLC

Tax Incentives for Green Energy Projects Come With a Lot of Strings Attached

Amundsen Davis LLC on

On August 29, 2023, Clock on Grassthe U.S. Department of the Treasury and the Internal Revenue Service (IRS) released more guidance and proposed rules on key provisions in the Inflation Reduction Act (IRA) that requires...more

Cadwalader, Wickersham & Taft LLP

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

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Clean Energy Tax Credits/Inflation Reduction Act: American Clean Power Association Comments Addressing Proposed...

The Inflation Reduction Act (“IRA”) included provisions addressing the transferability of clean energy tax credits. Prior to the enactment of these IRA provisions, it was not possible to monetize federal tax credits...more

Seyfarth Shaw LLP

The IRS – Finally – Publishes a Notice of Proposed Rulemaking Clarifying Inflation Reduction Act Prevailing Wage and...

Seyfarth Shaw LLP on

Seyfarth Synopsis: This alert summarizes the IRS’s recent notice of proposed rulemaking on complying with prevailing wage and apprenticeship requirements under the Inflation Reduction Act and explains key provisions...more

Allen Barron, Inc.

The US Treasury Department and IRS Have Released New Proposed Regulations on Sales and Exchanges of Digital Assets

Allen Barron, Inc. on

The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more

Cadwalader, Wickersham & Taft LLP

Is Treasury Tilting at Windmills with their Proposed Rules on Clean Energy Tax Credit Transfers?

Last August, the Inflation Reduction Act of 2022 (the “IRA”) introduced transferability provisions that will allow developers to sell clean energy tax credits.  On June 14, 2023, the IRS released proposed regulations and...more

Seyfarth Shaw LLP

My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Shaw LLP on

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

King & Spalding

Joint Proposed Rule Aims to Increase Consumer Protections Under the Affordable Care Act

King & Spalding on

HHS, the Department of Labor’s Employee Benefits Security Administration, and the Internal Revenue Service (IRS) (collectively, the Departments) issued a proposed rule on July 7, 2023, aimed at shoring up consumer protections...more

Groom Law Group, Chartered

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

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

Foley & Lardner LLP

Electrified Industrial Policy: IRS Proposed Regulations on Section 30D EV Tax Credits & EV Manufacturing Grants

Foley & Lardner LLP on

The Inflation Reduction Act of 2022 (the “IRA”) and the Infrastructure Investment and Jobs Act of 2021 (the “IIJA”) set in motion an ongoing series of changes that are aimed at transforming, among other things, the automotive...more

Bracewell LLP

Treasury Department and IRS Issue Additional Guidance on the New Low-Income Communities Bonus Credit Program

Bracewell LLP on

The low-income communities bonus credit (the LIC Bonus), which was introduced by the Inflation Reduction Act of 2022 (the IRA), provides an enhanced tax credit for certain wind and solar facilities located in designated...more

Latham & Watkins LLP

IRS Proposed Rules Explain How Taxpayers Can Buy and Sell Renewable Energy Tax Credits or Receive Cash Refunds

Latham & Watkins LLP on

The proposed rules for monetizing tax credits should catalyze energy transition markets and offer an alternative to tax equity transactions. On June 14, 2023, the IRS issued proposed rules for how it intends to administer...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Rules Regarding Direct Payment and Transferability of Certain Energy Tax Credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released two notices of proposed rulemaking regarding the direct payment of certain energy tax credits under Section 6417 of...more

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