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Cozen O'Connor

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status

Cozen O'Connor on

The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

Allen Barron, Inc. on

New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...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

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

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

White and Williams LLP

You Have Questions…SBA Releases PPP Loan Forgiveness FAQs

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The U.S. Small Business Administration (SBA), in consultation with the U.S. Department of the Treasury (Treasury), recently released a series of Frequently Asked Questions (the Forgiveness FAQs) focusing on forgiveness of...more

Hinshaw & Culbertson LLP

New Supplemental Guidance Issued for PPP Loan Program

On August 4, 2020, the Small Business Administration (SBA) and the U.S. Department of the Treasury released new FAQs to provide further guidance on Paycheck Protection Program (PPP) loan questions and supplement previously...more

Chambliss, Bahner & Stophel, P.C.

Finally! Initial PPP Loan FAQs Released

This afternoon, the Small Business Administration (SBA) and the Treasury Department published a set of frequently asked questions concerning forgiveness of loans under the Paycheck Protection Program (PPP). The new FAQs...more

Perkins Coie

IRS to Target High Net Worth Individuals, Private Foundations, and Associated Entities Beginning in July 2020

Perkins Coie on

The Internal Revenue Service (IRS) intends to audit hundreds of high net worth individuals and their related entities starting this month. The campaign, announced at a conference by a top IRS division commissioner, will...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

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

New Guidance for Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open to Additional Guidance

The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more

Bracewell LLP

Application of Partnership Audit Rules to Private Funds

Bracewell LLP on

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more

Williams Mullen

Interim Guidance Issued on New Business Interest Expense Limitations

Williams Mullen on

The IRS and the Treasury Department recently announced interim guidance to help taxpayers comply with the new business interest expense limitations under the Tax Cuts and Jobs Act (P.L. 115-97) (the “Act”). Notice 2018-28,...more

Dechert LLP

Reissuance of Proposed Regulations on Partnership Audit Rules

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service (the “IRS”) have re-issued proposed regulations (the “Proposed Regulations”) on the new centralized partnership audit rules enacted as part of the Bipartisan...more

Proskauer Rose LLP

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

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