News & Analysis as of September 18, 2024

Internal Revenue Service

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IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

Holland & Knight LLP on 5/9/2024

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

Eversheds Sutherland (US) LLP on 8/18/2022

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Eversheds Sutherland (US) LLP on 5/27/2021

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

McDermott Will & Emery on 8/7/2020

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

IRS offers a 162(m) - brace for the holidays

Eversheds Sutherland (US) LLP on 12/23/2019

On December 16, 2019, the Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released long-awaited proposed regulations under Section 162(m) of the Internal Revenue Code implementing changes...more

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