News & Analysis as of

U.S. Treasury Tax Reform

Paul Hastings LLP

Treasury Issues Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

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The Alternative Fuel Vehicle Refueling Property Credit available under Section 30C of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section 30C Credit”), was originally enacted by the...more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

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Gray Reed

IRS Further Combats Basket Contract Transactions with Proposed Regs

Gray Reed on

The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

A&O Shearman

Navigating the new elective safe harbor for the Domestic Content Bonus Tax Credit

A&O Shearman on

The U.S. Treasury Department and the Internal Revenue Service have issued a new safe harbor that will make it easier for U.S. solar, onshore wind and battery storage projects with U.S.-sourced components to qualify for...more

Cadwalader, Wickersham & Taft LLP

IRS Hints at Revolution in Tax-Free Spin-Off Rules, Ruling Practice

Over the last three months, public statements by U.S. Treasury and Internal Revenue Service officials have suggested that they are in the process of significantly revising the rules governing tax-free spin-offs, split-offs...more

Brownstein Hyatt Farber Schreck

White House FY2025 Budget Request: Key Tax Takeaways

On Monday, March 11, President Joe Biden released his budget request to Congress (“Budget”) and various accompanying documents. Separately, the Treasury Department released its General Explanations of the Administration’s...more

Brownstein Hyatt Farber Schreck

Fiscal Year 2025 Greenbook Provisions Chart

On Monday, March 11, President Joe Biden released his budget request to Congress (“Budget”) and various accompanying documents. Separately, the Treasury Department released its General Explanations of the Administration’s...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

A&O Shearman

U.S.-Chile Income Tax Treaty Enters Into Force

A&O Shearman on

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...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

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Cadwalader, Wickersham & Taft LLP

Treasury Delivers Mother Lode of Tax Reporting Rules to the Crypto Industry’s Doorstep

On August 29, 2023, the IRS published detailed proposed regulations addressing digital asset broker reporting requirements (the “Proposed Regulations”). The Proposed Regulations elaborate on the 2021 changes to the Internal...more

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Fenwick & West LLP

Treatment of Capitalized R&D Costs under Section 174 on a Disposition of IP: The Other Shoe to Drop

Fenwick & West LLP on

One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...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

McDermott Will & Emery

Weekly IRS Roundup May 22 – May 26, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 22, 2023 – May 26, 2023. ...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Brownstein Hyatt Farber Schreck

IRS Releases Long-Awaited Spending Plan for $80 Billion in New Inflation Reduction Act Funding

On Thursday, April 6, the Treasury Department and Internal Revenue Service (IRS) issued their long-term Strategic Operating Plan (SOP), outlining how the IRS intends to spend $79.4 billion in funding provided by the Inflation...more

Mayer Brown

US Treasury to Propose Regulations on Energy Community Bonus Adders

Mayer Brown on

On April 4, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on qualifying for the energy community bonus credit under Sections...more

Littler

Treasury Department’s Greenbook Discusses Tax Treatment of On-Demand Pay

Littler on

The U.S. Department of the Treasury has released a document to explain the revenue proposals included in President Biden’s FY 2023 proposed Budget.  For the second consecutive year, the General Explanations of the...more

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