In CCA 201928014 (July 12, 2019), the IRS Office of Chief Counsel provides its view of the interplay between the net operating loss (NOL) carryover rules set forth in Internal Revenue Code (Code) § 172(b)(2) and the...more
On June 20, 2019, the Court of Federal Claims released its opinions in the consolidated cases of California Ridge Energy, LLC v. U.S., C/A 1:14-cv-00250-RHH, and Bishop Hill Energy, LLC v. U.S., C/A 1:14-cv-00251-RHH. The...more
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities designated as “Opportunity Zones.”...more
The proposed regulations under section 168(k) issued by Treasury and the Internal Revenue Service (IRS) on August 3, 2018, not only presented utilities with some surprises, but also raised concerns as a result of unaddressed...more
Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more