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Limited initial guidance issued for section 48(e) investment tax credit enhancer

On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (Service) issued Notice 2023-17 (Notice), establishing the 48(e) Low-Income Communities Bonus Credit Program (Program) with respect...more

Treasury and the IRS provide initial guidance on section 48C ITC for manufacturers

On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-18 (Notice), which establishes the program to allocate $10 billion of tax credits that were added by the...more

US Treasury issues notice to Hungary to formally withdraw from longstanding US-Hungary Income Tax Treaty

The US Treasury is moving to formally withdraw from the US-Hungary income tax treaty, which has been in effect since 1979 (the Treaty). For previous reporting by Eversheds Sutherland regarding the Treaty, see US-Hungary tax...more

BEAT, FATCA and Insurance - proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under...

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more

And the BEAT goes on – proposed regulations clarify the application of the base-erosion and anti-abuse tax

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as...more

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