News & Analysis as of

Regulatory Standards Internal Revenue Code (IRC)

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

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

King & Spalding on

On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more

Gray Reed

IRS Fails to Follow its Own Procedures and IRS Counsel Claims Supervisory Approval Still Valid

Gray Reed on

Although the government bears the burden of production for penalties, this often involves nothing more than showing that the penalties were properly assessed. Penalty relief is usually only given when the taxpayer can marshal...more

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

S Election Terminated as a Result of Form Operating Agreement Language

A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more

Sheppard Mullin Richter & Hampton LLP

New Effort to Exempt Crypto Currency from Certain SEC, Tax and Other Regulatory Burdens

A new bill, the Token Taxonomy Act was introduced to congress to amend the Securities Act of 1933 and the Securities Exchange Act of 1934 to exclude digital tokens from the definition of a security, to direct the Securities...more

Poyner Spruill LLP

New Regulatory Developments in Blockchain Finance

Poyner Spruill LLP on

Blockchain technology combines several features of existing financial infrastructure. It is partly a mass repository of historical transactions, partly a decentralized clearinghouse, and partly a digital currency. It is also...more

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