On June 14, 2023, the Treasury Department and the Internal Revenue Service (IRS) released long-awaited guidance (the Credit Transfer Guidance) regarding the transfer of energy transition tax credits under Section 6418, which...more
6/23/2023
/ Anti-Abuse Rule ,
Compliance ,
Energy Tax Incentives ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Production Tax Credit ,
Proposed Regulation ,
S-Corporation ,
U.S. Treasury
Federal support for carbon capture, utilization and storage (“CCUS”) demonstrated over the last two months has generated even greater enthusiasm for carbon capture projects in the United States. First, in the final weeks of...more
Last week, in a pair of notices released under President Trump’s March 13, 2020 Emergency Declaration relating to the coronavirus pandemic, the IRS and the Treasury Department offered relief for tax return filing and tax...more
3/24/2020
/ Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
2/6/2019
/ Corporate Taxes ,
Income Taxes ,
IRS ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Private Letter Rulings ,
Push-Out Requirements ,
Tax Audits ,
Tax-Free Spin-Offs ,
U.S. Treasury ,
Venture Capital
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
9/20/2018
/ Anti-Avoidance ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Publicly-Traded Companies ,
REIT ,
SALT ,
Section 199 ,
Tax Cuts and Jobs Act ,
W-2
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
5/3/2018
/ Audits ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Private Equity Funds ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
TEFRA
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
4/17/2018
/ Bi-Partison Balanced Budget Act (BBA) ,
Corporate Taxes ,
Energy Sector ,
FCC ,
FIRPTA ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
IRS ,
Like Kind Exchanges ,
Loss-Carryover ,
Net Operating Losses ,
New Rules ,
Opt-Outs ,
Partnership Agreements ,
Partnerships ,
Push-Out Requirements ,
Tax Audits ,
Tax Cuts and Jobs Act
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
4/6/2018
/ Base Erosion Tax ,
C-Corporation ,
Corporate Taxes ,
Entertainment Industry ,
Foreign Affiliates ,
GILTI tax ,
Income Taxes ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
Renewable Energy ,
Tax Audits ,
Tax Deductions ,
Tax Liability
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/1/2018
/ Audits ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
FIRPTA ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
TEFRA ,
Underpayment
In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more
8/8/2017
/ Business Taxes ,
FIRPTA ,
Foreign Partner ,
Income Taxes ,
International Tax Issues ,
IRS ,
Non-US Entities ,
Partnership Interests ,
Partnerships ,
Tax Court ,
Tax Liability