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Tax Deductions U.S. Treasury Income Taxes

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

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

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

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)

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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

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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

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

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

ArentFox Schiff

Bipartisan Relief Bill Seeks to Allow Tax Deduction for PPP Loan Expenditures

ArentFox Schiff on

On Monday, December 14, Senator Joe Manchin (D-WV) and Senator Susan Collins (R-Maine) introduced the “Emergency Coronavirus Relief Act of 2020,” which would provide another round of relief to combat the economic fallout...more

BakerHostetler

Did the IRS Bless the Passthrough Entity Workaround to the $10K SALT Cap?

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For three years, states and taxpayers have been looking for novel ways to get around the federal TCJA's $10,000 cap on deducting state and local taxes. The IRS just released Notice 2020-75, which appears to bless states'...more

White and Williams LLP

IRS to Allow “Workaround” to Deduction Limits for State and Local Income Taxes

White and Williams LLP on

The Tax Cuts and Jobs Act (2017 Tax Act) limited the deduction of state and local taxes to $10,000 for individuals. Several states, including Connecticut, New Jersey and Maryland, have passed legislation that imposed income...more

Lowndes

New Treasury and IRS Regulations Bless SALT Deductions for Pass-through Entities

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Monday, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued a press release and related notice regarding proposed regulations which clarify that the $10,000 cap on state and local tax (SALT)...more

Lowndes

IRS and Treasury Finalize Last Set of Bonus Depreciation Regulations

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One of the key tax benefits for investors and owners of real estate such a senior living facilities is depreciation.  The 2017 Tax Cuts and Jobs Act expanded on this benefit, allowing for 100% bonus depreciation for assets...more

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Clarify Business Interest Deduction Limitation

Background - On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

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The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

A&O Shearman

Final BEAT Deduction Waiver Regulations Provide Some Relief

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On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the...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

McAfee & Taft

Every action has a reaction, even in the tax world - Gavel to Gavel

McAfee & Taft on

The Tax Cuts and Jobs Act of 2017 limited the state and local taxes paid deduction available to individual taxpayers to $10,000. The deduction is most notably taken by Oklahomans on their federal tax return to deduct state...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

McDermott Will & Emery

Weekly IRS Roundup September 16 – 20, 2019

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 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – 23, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Bradley Arant Boult Cummings LLP

A More Viable SALT Cap Workaround? Pass-Through Entity-Level Taxes - Bloomberg Tax

Now that the Treasury Department and Internal Revenue Service have issued ?nal regulations to address at least some variations of so-called ‘‘SALT cap workarounds’’ to the Tax Cuts and Jobs Act’s limitation on individual...more

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