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Treasury and IRS release domestic content guidance for renewable energy tax credits

On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2023-38 to provide guidance on the domestic content requirements under IRC sections 45, 45Y, 48, and 48E....more

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

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

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

A new life for leveraged partnership structures; Treasury and the IRS issue proposed regulations under the disguised sale rules

On June 19, 2018, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-131186-17) (2018 Proposed Regulations) concerning the manner in which partnership liabilities are allocated among the...more

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