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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

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

Mayer Brown on

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

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

BakerHostetler on

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

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

ArentFox Schiff on

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

Warner Norcross + Judd

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

Warner Norcross + Judd on

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

Dechert LLP

Final IRS Regulations on Transition from LIBOR to Other Reference Rates

Dechert LLP on

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

Mintz - Public Finance Viewpoints

Treasury and IRS Release Final Tax Regulations for LIBOR Replacement Amendments

The lengthy saga of the transition to a post-LIBOR world reached a degree of finality on the tax side with the issuance by the Department of Treasury and Internal Revenue Service (IRS) of long-awaited final regulations (the...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Gould + Ratner LLP

IRS Finalizes Carried Interest Regulations

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The IRS and Treasury Department released final regulations on January 7, 2021, that govern the tax treatment of partnership and LLC interests related to services, so-called carried interests, a/k/a applicable partnership...more

Perkins Coie

Final Regulations Issued Regarding Section 45Q Tax Credits Carbon Oxide Sequestration

Perkins Coie on

The U.S. Department of the Treasury and the Internal Revenue Service on January 6, 2021, issued Treasury Decision 9944, providing final regulations relating to Section 45Q tax credits (Regulations). The Regulations provide...more

Bracewell LLP

IRS and Treasury Department Release Final Regulations Regarding Like-Kind Exchanges

Bracewell LLP on

On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of...more

McDermott Will & Emery

Government Revises Base Difference Rules in New Foreign Tax Credit Regulations

McDermott Will & Emery on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9922) (the 2020 Final Regulations) and related proposed regulations (REG-101657-20) (the...more

McDermott Will & Emery

IRS Issues Final Regulations Concerning Withholding on Partnership Interest Transfers

McDermott Will & Emery on

The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more

McDermott Will & Emery

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Emery on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

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The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

McDermott Will & Emery

Government Releases Second Tranche of Final Regulations on BEAT

McDermott Will & Emery on

On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...more

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

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Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

Tonkon Torp LLP

IRS Proposes New 1031 Regulations – Sculptures Are Real Property, Walls Are Not

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The IRS issued Proposed Regulation 117589-18 on June 11, 2020 (the “Proposed Regs”), in response to legislative changes applicable to like-kind exchange transactions (“1031s”). The Proposed Regs address transactions involving...more

McDermott Will & Emery

Government Releases Final Regulations on FDII and GILTI Deduction

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On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more

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