Frank Comparetto III

Eversheds Sutherland (US) LLP

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Tax Bytes: Week of July 7, 2025

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

7/10/2025 / Corporate Taxes , Energy Policy , Energy Projects , Energy Tax Incentives , Inflation Reduction Act (IRA) , New Legislation , Tax Credits , Tax Cuts and Jobs Act , Tax Reform , Trump Administration

Biden’s second (attempted) bite at the private equity apple: Key 2023 Green Book proposals impacting private equity funds and...

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the Budget) followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals....more

4/4/2022 / Biden Administration , Corporate Taxes , Federal Budget , Green Book , Investors , Private Equity Funds , Tax Revenues

Treasury and the IRS address classification and ordering rules for previously taxed earnings and profits of foreign corporations

On December 14, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance (Notice 2019-01 or the Notice) describing proposed regulations that they intend to issue addressing...more

1/7/2019 / Business Profits , Corporate Taxes , Earnings Tax , Foreign Corporations , Income Taxes , Internal Revenue Code (IRC) , IRS , Proposed Regulation , U.S. Treasury

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

12/20/2018 / Base Erosion Tax , Corporate Taxes , Foreign Corporations , IRS , Proposed Regulation , U.S. Treasury

Allocation, apportionment and attribution, oh my – Proposed foreign tax credit regulations provide critical guidance

On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take...more

12/6/2018 / Controlled Foreign Corporations , Corporate Taxes , Foreign Tax Credits , GILTI tax , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Tax Cuts and Jobs Act , U.S. Treasury

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