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U.S. Treasury Revenue Procedures Internal Revenue Service

Eversheds Sutherland (US) LLP

Short tax year savior: Rev. Proc. 2024-34

Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes - On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more

McDermott Will & Emery

Weekly IRS Roundup August 12 – August 16, 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 12, 2024 – August 16, 2024. ...more

Fenwick & West LLP

Treasury’s Crypto Tax Reporting Rules Defer on DeFi

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On June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final broker reporting regulations that mandate broker reporting for centralized exchanges and hosted wallet providers, providing...more

Skadden, Arps, Slate, Meagher & Flom LLP

New IRS Ruling Guidelines Significantly Impact Tax-Free Spin-Offs

On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations and Revenue Procedure on the Clean Vehicle Tax Credits under Section 30D of...

The proposed regulations add new definitions to clarify what is required under foreign entity of concern (FEOC) compliance. The Revenue Procedure provides guidance to qualified manufacturers on reporting and other...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

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The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

McDermott Will & Emery

Weekly IRS Roundup November 6 – November 10, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023...more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations and Procedures for Clean Vehicle Credit Transfers

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Oct. 6, 2023, released proposed regulations on the transfer of clean vehicle credits under Internal Revenue Code Section 25E (for previously owned clean vehicles) and Section 30D...more

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

Vinson & Elkins LLP

Treasury Issues Final Regulations on Low-Income Communities Bonus

Vinson & Elkins LLP on

On August 10, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations (the “Final Regulations”)1 providing additional guidance to taxpayers on the “Low-Income...more

Lowndes

Applications for Low-Income Communities Bonus Tax Credits to Open in Early Fall

Lowndes on

Last year’s Inflation Reduction Act created the Low-Income Communities Bonus Credit Program. This program provides additional energy tax credits on top of the existing 30% investment tax credit. According to Section 48(e) of...more

Jones Day

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

Jones Day on

A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

McDermott Will & Emery

Weekly IRS Roundup June 12 – June 16, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 12, 2023 – June 16, 2023...more

McDermott Will & Emery

Weekly IRS Roundup May 30 – June 2, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 30, 2023 – June 2, 2023....more

Holland & Knight LLP

Eyes on Energy Tax Update: January 2023

Holland & Knight LLP on

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The fourth quarter of 2022 brought a flurry of energy tax...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

McDermott Will & Emery

Weekly IRS Roundup December 12 – December 16, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

McDermott Will & Emery

IRS Hints at Revenue Procedure 94-69 Update

McDermott Will & Emery on

At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more

McDermott Will & Emery

IRS Appeals Will Not Consider Regulatory Invalidity and Subregulatory Procedural Invalidity Challenges

McDermott Will & Emery on

In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like they do to other federal agency...more

Miller Canfield

Disregarding Administrative Tax Guidance Aided the IRS in Two Cases and the Taxpayer in a Third Case

Miller Canfield on

​​​​​​​Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more

Eversheds Sutherland (US) LLP

A Timely Update: The IRS and Treasury release Rev. Proc. 2022-14 updating list of automatic accounting method changes

Section 446(e) requires a taxpayer to obtain IRS consent prior to changing its accounting method. A change in method of accounting may include either a change in an overall plan of accounting for gross income or deductions...more

Eversheds Sutherland (US) LLP

Anticipating the end: IRS finalizes LIBOR transition guidance

Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more

Morgan Lewis

IRS FAQs: A Potential Shield for Taxpayers—Not a Sword for the Service

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The IRS recently issued guidance on the utility of and weight to be afforded informal “frequently asked questions” (FAQs) published on its website—clarifications that became necessary given the IRS’s heavy reliance on FAQs as...more

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