News & Analysis as of

Proposed Regulation U.S. Treasury NPRM

Sheppard Mullin Richter & Hampton LLP

Soil and Security: The Broadening Scope of CFIUS in Real Estate Transactions

As the Committee on Foreign Investment in the United States (CFIUS) continues to expand its jurisdictional reach, investors, property owners, and landlords should be aware of a growing focus on real estate transactions....more

White & Case LLP

Proposed Regulations Issued for Outbound Investment Program: Key Takeaways

White & Case LLP on

On June 21, 2024, the US Department of the Treasury issued a Notice of Proposed Rulemaking (“Proposed Rule”) to implement Executive Order 14105 (“EO”) establishing a new Outbound Investment Program ("OIP") to prohibit or...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

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

Sheppard Mullin Richter & Hampton LLP

Proposed Outbound Investment Regulations: Understanding the New Restrictions on U.S. Outbound Investments in Artificial...

In an era where technological prowess and economic security are more entangled than ever, the United States has refined its approach towards restricting outbound investments. As we have been blogging since 2022, the past two...more

Sheppard Mullin Richter & Hampton LLP

Treasury Department Proposes to Sharpen the Teeth of CFIUS Enforcement

Key Takeaways: The Treasury Department is seeking to equip CFIUS with greater enforcement and oversight authority. These new powers include the ability to request more information from transaction parties and also to assess...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more

Holland & Knight LLP

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

Holland & Knight LLP on

The U.S. Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released much-anticipated guidance in the form of two notices of proposed rulemaking (NOPRs) regarding the direct payment of tax...more

Eversheds Sutherland (US) LLP

Ready, Set, Sequester? An updated guide to the Section 45Q Carbon Capture and Sequestration Credit Guidance

Section 45Q, as amended by the Bipartisan Budget Act of 2018 (BBA), provides a substantial tax credit for the capture and sequestration of carbon dioxide and other carbon oxides. Taxpayers have been awaiting guidance from the...more

Proskauer - Tax Talks

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

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