Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more
10/24/2024
/ Entity Classification ,
Income Taxes ,
Indian Reorganization Act ,
Inflation Reduction Act (IRA) ,
IRS ,
New Regulations ,
Proposed Regulation ,
Regulatory Agenda ,
Tribal Corporations ,
Tribal Governments ,
U.S. Treasury
On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more
On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more