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Troutman Pepper

IRS Issues Final Regulations on Prevailing Wages and Registered Apprenticeship Requirements

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On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing...more

Cadwalader, Wickersham & Taft LLP

Finally Final Crypto Reporting Regulations

On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

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On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

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

Treasury, Internal Revenue Service Issue Final Regulations for Transfer of Energy Credits

On April 25, 2024, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations regarding the transfer of energy tax credits under the Inflation Reduction Act of 2022 (IRA)....more

Mayer Brown

US Treasury Releases Final Regulations Addressing Domestic Control Determinations Under FIRPTA

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On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more

Kaufman & Canoles

ESOP Community Waits for DOL Regulation on Valuation with Hope and Dread

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As part of the comprehensive “SECURE 2.0” retirement plan legislation enacted in December 2022, Congress directed the U.S. Department of Labor (DOL) to issue a long delayed and much needed regulation defining the term...more

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

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As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Foley & Lardner LLP

IRS Releases Final Direct Pay Regulations

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The Internal Revenue Service (“IRS”) and Department of the Treasury earlier this week released final regulations relating to direct cash payments for certain tax credits pursuant to Section 6417 of the Internal Revenue Code...more

ArentFox Schiff

What Private Companies Need To Consider in 2024: Top 10 Legal Issues

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Private companies and their owners face ever-evolving challenges as the market sees new regulations, new deal trends, and new risks in 2024. Below are 10 issues that the owners and leaders of privately held companies should...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Insights: Other Regulatory Developments

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more

Foley & Lardner LLP

Mexican Government Restricts Importation of Certain Fuels and Petrochemicals into Mexico

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On October 23, 2023, the Mexican President published in the Official Gazette of the Federation a Decree under which the Mexican Government implements measures to combat the illicit trading of fuels, related to the importation...more

ArentFox Schiff

IRS, Treasury Release Final Regulations Impacting Type I and Type III Supporting Organizations

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The Internal Revenue Service (IRS) and the US Department of the Treasury released final regulations on October 16 that address the changes enacted by the Pension Protection Act of 2006 (PPA). The regulations provide...more

Kohrman Jackson & Krantz LLP

Artificial Intelligence Allows IRS to Increase Scrutiny of High-Earners & Partnerships

The Internal Revenue Service (IRS) recently announced a renewed effort to ensure compliance with federal tax law, specifically focusing on high-income earners, partnerships, and large corporations. This additional scrutiny...more

Pillsbury Winthrop Shaw Pittman LLP

New Digital Asset Regulations Provide Glimmers of Much-Needed Clarity

The proposed regulations under the Infrastructure Investment and Jobs Act (IIJA) expand the definition of “broker” to include anyone who provides facilitative services which effectuate sales. Not surprisingly, centralized...more

Warner Norcross + Judd

Proposed Treasury Regulations Impose Hard Deadline and Requirements on Forfeitures in Defined Contribution Plans

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The U.S. Department of the Treasury has recently proposed new regulations that clarify when and for what purposes defined contribution plans — such as 401(k) plans — may use forfeitures. These regulations are proposed to...more

Fenwick & West LLP

IRS Delays Infrastructure Act's Broker Reporting Requirements

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On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Holland & Hart - The Benefits Dial

We Are Family – IRS Regulations Fix the “Family Glitch” in Connection with ACA Coverage

One of the key remaining features of the Affordable Care Act (ACA) is that certain employers must offer their employees medical coverage, or else pay a penalty. The details of that “employer shared responsibility payment”...more

Trusaic

Final Regulations Amend Eligibility for Premium Tax Credits

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The IRS recently issued final regulations on the use of Premium Tax Credits (PTCs), resolving the “family glitch” and extending PTC eligibility beyond individuals to family members.  As a result, individuals and their...more

ArentFox Schiff

FinCEN Issues Final Rules & Regulations for CTA

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Knowing who owns legal entities is essential to stopping terrorism, money laundering, and other sophisticated criminal enterprises. For entities formed in the United States there has never been a requirement to disclose...more

Kaufman & Canoles

ESOPs & Employee Benefits Q2 2022 Client Update

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Happy Summer from the K&C ESOPs & Employee Benefits practice group. We’ve compiled a short list of employee benefits updates from the second quarter of 2022....more

Freeman Law

Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit.

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As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the U.S. tax system to reduce the impact of double taxation. In general terms, income that is derived from a foreign jurisdiction by a U.S....more

Dechert LLP

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

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The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered modifications,” as defined, of certain...more

Partridge Snow & Hahn LLP

IRS Issues Final Regulations on Transition from IBORs to Other Reference Rates

The IRS has issued final regulations governing the tax consequences of transitions from Interbank Offered Rates (IBORs) to other reference rates in debt instruments. The final regulations adopt many of the proposed...more

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