News & Analysis as of

S-Corporation U.S. Treasury 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

Paul Hastings LLP

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

Holland & Hart LLP

Top 10 Things to Know: Proposed Regs for Renewable Energy Direct Pay & Direct Transfer

Holland & Hart LLP on

On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

Paul Hastings LLP on

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

McDermott Will & Emery

Weekly IRS Roundup September 20 – 24, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

Cole Schotz on

The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Katten Muchin Rosenman LLP

Additional Proposed Regulations Issued Regarding Opportunity Zones

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Latham & Watkins LLP on

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Verrill

Tax Alert: Understanding the New Pass-Through Business Deduction Rules Under Code Section 199A

Verrill on

Due to the significant changes to the Internal Revenue Code (“Code”) made by the Tax Cuts and Jobs Act (“Tax Act”) at the end of last year, the Department of the Treasury has been very busy issuing guidance and proposed...more

McGuireWoods LLP

IRS and Treasury Issue Regulations on “50(d) Income” Affecting Tax Credit Deals

McGuireWoods LLP on

The Internal Revenue Service and Department of Treasury recently issued final and temporary regulations on income inclusion under Section 50(d) of the Internal Revenue Code as it relates to the tax credit industry. The...more

Proskauer Rose LLP

Valuation Discounts for Transfers of Interests in Family Entities May Be Severely Curtailed – You May Want To Act Now

Proskauer Rose LLP on

On August 2, 2016, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations under section 2704 (the "Proposed Regulations") of the Internal Revenue Code of 1986, as amended (the...more

K&L Gates LLP

New Temporary Regulations Deny Basis Increase in Partnership Interests in Lease Passthrough ITC Structures

K&L Gates LLP on

On July 21, the U.S. Treasury Department (“Treasury”) released temporary and proposed regulations denying a basis increase to equity holders of lessee partnerships and S corporations to account for mandatory income inclusions...more

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