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Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

Baker Donelson

SALT Select Developments - March 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Baker Donelson

SALT Select Developments - February 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Bodman

Michigan Enacts Elective Flow-Through Entity Tax as “SALT Cap Workaround”

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On Monday, December 20, 2021, Michigan Governor Gretchen Whitmer signed House Bill (H.B.) 5376 into law.  H.B. 5376, also referred to as Michigan’s “SALT Cap Workaround,” amends the Michigan Income Tax Act to allow...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

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On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

McGlinchey Stafford

No Partner/S-Corp Shareholder SALT Deduction Limit On Entity Income Taxes

McGlinchey Stafford on

The Internal Revenue Service has announced that it will be issuing proposed regulations clarifying that certain state or local income taxes imposed on and paid by a partnership and/or an S corporation will not be subject to...more

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

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On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

Holland & Hart LLP

IRS Publishes Guidance on the Carbon Capture Tax Credit

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On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Eversheds Sutherland (US) LLP

Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit

In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit. Beginning of Construction Guidance—Notice 2020-12. Partnership Allocation Guidance—Revenue Procedure...more

Akin Gump Strauss Hauer & Feld LLP

Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors

The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Emery

Weekly IRS Roundup January 21 – 25, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 21 – 25, 2019. Tax news is very limited because of the government shutdown: January 22,...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

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Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

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• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Smith Anderson

Draft North Carolina Tax Legislation Released

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On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

Orrick, Herrington & Sutcliffe LLP

Energy Taxation: Impact Of The Tax Cuts And Jobs Act

Congress has passed the tax reform bill, known as the "Tax Cuts and Jobs Act", and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law that affect many industries. ...more

Pillsbury Winthrop Shaw Pittman LLP

The Impact of the Tax Cuts and Jobs Act on LIHTC Investments

The Tax Cuts and Jobs Act contains changes impacting the LIHTC Program. While the low-income housing tax credit program emerged largely unscathed, the reduction in corporate tax rates will reduce equity pricing. ...more

Dechert LLP

Proposed Tax Legislation - Highlights for Investment Funds

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The final version of the proposed Tax Cuts and Jobs Act (the “Act”) was released on December 15, 2017. This legislation, unless amended again, is expected to be voted on this week in the U.S. House of Representatives and the...more

Alston & Bird

Proposed Tax Regulations Address International Aspects of the New Partnership Audit Regime

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We are about to witness an almost unprecedented centralized partnership audit regime that takes full effect for taxable years starting on or after January 1, 2018, as adopted in late 2015 by Section 1101 of the Bipartisan...more

Jones Day

House of Representatives Releases First Draft of Tax Reform Bill

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The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

Williams Mullen

The Cost of Clarity: IRS Issues Regulations Addressing Proper Treatment of Code Section 50(d) Income

Williams Mullen on

On July 21, 2016, the IRS issued long-awaited regulations under Section 50 of the Internal Revenue Code (the “Code”) clarifying the manner in which “Section 50(d) Income” is to be recognized in lease pass-through investment...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Eversheds Sutherland (US) LLP

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

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