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Tax Deductions U.S. Treasury

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

McDermott Will & Emery

Weekly IRS Roundup August 5 – August 9, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more

Freeman Law

Treasury Department and IRS Target Partnership Basis-Shifting Transactions

Freeman Law on

On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

Polsinelli on

In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

Rivkin Radler LLP on

Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

McDermott Will & Emery on

McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Brownstein Hyatt Farber Schreck

Taxation and Representation, March 28, 2023

Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...more

McDermott Will & Emery

Weekly IRS Roundup March 13 – March 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

Parker Poe Adams & Bernstein LLP

How Real Estate Developers Can Benefit From a New Tax Rule

The Internal Revenue Service has now made it much easier for real estate developers across asset classes to benefit from the alternative cost method. It enables multi-unit developers to receive tax benefits for common...more

Katten Muchin Rosenman LLP

Treasury Releases Guidance on Electric Vehicle Tax Credits

On December 29, 2022, the US Treasury Department and the Internal Revenue Service (IRS) released guidance relating to the electric vehicle (EV) tax credit provisions of the Inflation Reduction Act of 2022, Public Law 117-169...more

McDermott Will & Emery

Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

McDermott Will & Emery on

On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on foreign tax credits (the “Final Regulations”) since the enactment of the Tax Cuts...more

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

McDermott Will & Emery

Weekly IRS Roundup October 25 – October 29, 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 October 25, 2021 – October 29, 2021... October 25, 2021: The IRS released a memorandum...more

McDermott Will & Emery

Weekly IRS Roundup September 13 – 17, 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 13, 2021 – September 17, 2021... September 13, 2021: The IRS issued a news release...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Fox Rothschild LLP

DANTE’S DEDUCTION: Or Did You Mean A Credit?

Fox Rothschild LLP on

There is hope that the plague is behind us. Pestilence is on its way either in the form of a lantern fly or the return of the cicada after 17 years of peace. For the divorce lawyer and his friend in crime, the accountant,...more

Eversheds Sutherland (US) LLP

State of play: A May methods update 

At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more

Ervin Cohen & Jessup LLP

IRS Issues Guidance on Business Meal Deductions

On April 8, 2021, the Treasury Department and the Internal Revenue Service issued guidance regarding the temporary 100-percent deduction for food and beverage purchased from restaurants. Beginning January 1, 2021,...more

Lowenstein Sandler LLP

Paycheck Protection Program: FAQs For Microbusinesses - UPDATED March 2021 #3

On December 27, the President signed into law the Consolidated Appropriations Act, 2021. The Act includes a roughly $900 billion COVID-19 relief package, known as the “Economic Aid to Hard-Hit Small Businesses, Nonprofits and...more

Lowenstein Sandler LLP

Paycheck Protection Program: FAQs For Microbusinesses - UPDATED March 2021 #2

Lowenstein Sandler LLP on

On December 27, the President signed into law the Consolidated Appropriations Act, 2021. The Act includes a roughly $900 billion COVID-19 relief package, known as the “Economic Aid to Hard-Hit Small Businesses, Nonprofits and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more

WilmerHale

Final Section 162(f) Regulations Liberalize Opportunities to Deduct Disgorgement and Other Payments Made in Government...

WilmerHale on

On January 12, 2021, the Internal Revenue Service (IRS) and the Treasury Department released final regulations governing the deductibility of certain fines, penalties and other amounts paid to, or at the direction of, a...more

Groom Law Group, Chartered

Treasury Issues Final Regulations on Section 162(m) Executive Compensation Deduction Limits

On December 18, 2020, the Internal Revenue Service (“IRS”) and Treasury Department released final regulations (the “Final Regulations”) interpreting the Tax Cuts and Jobs Act’s (the “Act’s”) revisions to Section 162(m) of the...more

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