New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new campaigns continue the IRS’s move to...more
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The announcement of these new campaigns reiterates LB&I’s efforts to focus...more
New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The five campaigns supplement the 13 initial...more
On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the TCJA), the most substantial overhaul of the Internal Revenue Code since 1986. The TCJA significantly changes how the US taxes individuals,...more
On November 2, 2017, the House Ways and Means Committee released a draft of the Tax Cuts and Jobs Act (the House proposal). On November 9, Senate Finance Committee (SFC) Chairman Orrin Hatch (R-UT) released a summary of the...more
As noted in a previous Eversheds Sutherland Legal Alert, on November 2, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the House Bill). An amended version of the House Bill (the Ways and...more
On November 9, 2017, the Senate Finance Committee (SFC) released a summary of its initial draft tax proposal (the Senate proposal). While the Senate proposal is similar to the House Ways and Means Committee’s proposal (the...more
On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more
The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more
On September 7, 2017, the IRS issued Revenue Procedure 2017-47, which provides a safe harbor for regulated public utilities for inadvertent or unintentional uses of a practice or procedure that is inconsistent with the...more
On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more
Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more
On March 27, 2017, the U.S. District Court for the Southern District of Florida ruled that disposal fees paid by NextEra Energy Inc. and its subsidiary, Florida Power & Light Co. (NextEra or taxpayer) into the Nuclear Waste...more
In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more
On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations...more
On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property...more