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 June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...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
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
6/12/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Cryptoassets ,
Financial Institutions ,
Financial Services Industry ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
IRS ,
OECD ,
Reporting Requirements ,
Tax Credits ,
Tax Cuts and Jobs Act
On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more
5/15/2025
/ Amortization ,
Bonus Depreciation ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
EBITDA ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Legislation ,
Research and Development ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Ways and Means Committee
Tax developments -
Actavis and deductible expenses -
On March 21, 2025, the Court of Appeals for the Federal Circuit released a decision in Actavis Laboratories FL, Inc. v. United States, holding that taxpayers could...more
On November 5, 2024, Judge Goeke of the United States Tax Court issued an order granting the petitioners’ Motion for Reconsideration of Findings (Motion) in Schwarz v. Commissioner. On May 13, 2024, the Tax Court released...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 July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more
8/14/2024
/ Appeals ,
Chevron Deference ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Statutory Interpretation ,
U.S. Treasury
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
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
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
[unable to retrieve full-text content]On April 25, 2024, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations on the transferability of certain tax credits under the...more
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
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