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 July 4, 2025, President Trump signed the One Big Beautiful Bill Act into law (the new law). The new law includes permanent extensions of three key business-favorable tax provisions from the 2017 Tax Cuts and Jobs Act...more
7/8/2025
/ Bonus Depreciation ,
Business Taxes ,
Corporate Taxes ,
Federal Budget ,
Investment ,
Legislative Agendas ,
New Legislation ,
Senate Finance Committee ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Trump Administration
On June 16, 2025, the Senate Finance Committee released proposed text for tax provisions to be included in the Senate’s version of the One Big Beautiful Bill Act (OBBB). Our prior Alert addresses the House version of the...more
6/18/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Bonus Depreciation ,
Business Taxes ,
Federal Budget ,
Proposed Legislation ,
Research and Development ,
SALT ,
Senate Finance Committee ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
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
5/21/2025
/ Business Taxes ,
EBITDA ,
Employee Benefits ,
Employee Retention ,
Excise Tax ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Reporting Requirements ,
Senate Committees ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Reform ,
U.S. House ,
Ways and Means Committee
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 -
DeFi regulations repealed -
On April 10, President Trump signed into law a bill repealing the regulations promulgated under section 6045 that would have required decentralized finance platforms...more
Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes -
On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...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
In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more
At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more
The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more
9/12/2023
/ Capital Expenditures ,
Interim Guidance ,
IRS ,
Proposed Regulation ,
Research and Development ,
Revenue Procedures ,
Software ,
Software Developers ,
Tax Cuts and Jobs Act ,
Technology Sector ,
U.S. Treasury
On June 15, 2023, the IRS released Rev. Proc. 2023-24, List of Automatic Changes, which provides an update to the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures....more
The Tax Cuts and Jobs Act (TCJA) included a sunset provision for immediate expensing of research and experimentation (R&E) expenditures, generally providing that such expenses would be subject to five-year (domestic R&E) or...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more
8/18/2022
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Financial Statements ,
GAAP ,
IFRS ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Rates
Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more
9/24/2021
/ Biden Administration ,
Congressional Committees ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Infrastructure ,
IRS ,
Proposed Legislation ,
Reconciliation ,
Research and Development ,
Research and Experiment Tax Credit ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
/ Accounting Methods ,
Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
GAAP ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
5/18/2021
/ American Bar Association (ABA) ,
Biden Administration ,
Business Losses ,
Cryptocurrency ,
Financial Reporting ,
Internal Revenue Code (IRC) ,
IRS ,
Legislative Agendas ,
Priority Guidance Plan ,
Section 162(f) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
U.S. Treasury
On Thursday, April 8, the IRS served up Notice 2021-25 (the Notice) providing guidance for taxpayers seeking to take advantage of the temporary 100-percent deduction for the cost of business meals, which was enacted by...more
On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more
Just in time to add to your holiday reading list, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations under sections 451(b) and 451(c) of the Code addressing income...more
On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more
Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...more