The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of...more
On April 17, 2019, the Department of Treasury and Internal Revenue Service released another set of proposed regulations on the Opportunity Zone (OZ) tax benefit. Until recently, many investors, funds, business owners and real...more
On Dec. 13, 2018, the Internal Revenue Service and Department of Treasury issued proposed regulations addressing the base erosion and anti-abuse tax (BEAT). In general, the regulations provide guidance for identifying an...more
Last week, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations concerning the designation and authority of a partnership representative under the centralized partnership audit regime...more
The Internal Revenue Service and Department of Treasury recently issued final and temporary regulations on income inclusion under Section 50(d) of the Internal Revenue Code as it relates to the tax credit industry. The...more