The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
7/21/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Congressional Committees ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EU ,
G7 ,
GILTI tax ,
International Tax Issues ,
IRS ,
Multinationals ,
OECD ,
Public Policy ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
US Trade Policies
The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more
7/14/2025
/ Corporate Counsel ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Legislative Agendas ,
Pass-Through Entities ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Taxation
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more
7/8/2025
/ Corporate Taxes ,
Employee Benefits ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Mortgage REITS ,
Opportunity Zones ,
Popular ,
Qualified Small Business Stock ,
Research and Development ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Legislation ,
Tax Reform ,
Trump Administration
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more
The IRS and Treasury on June 3 issued proposed regulations under Sections 45Y and 48E (proposed regulations), which address clean electricity production and investment tax credits, respectively, that generally replace...more
On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
3/13/2024
/ Energy Projects ,
Grants ,
IRS ,
Loans ,
New Regulations ,
Partnerships ,
Production Tax Credit ,
Registration Requirement ,
Renewable Energy ,
S-Corporation ,
Tax Credits ,
Tax Exempt Entities ,
Tax Returns ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
9/18/2023
/ Apprenticeships ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Penalties ,
Prevailing Wages ,
Production Tax Credit ,
Recordkeeping Requirements ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more
As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more
Key Takeaways:
..The law regarding computation of FBAR penalties is unclear.
..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts.
..Until the Supreme Court...more
In the past several years, the use and prevalence of virtual currency have increased exponentially. The proliferation of digital assets has changed the way goods and services are exchanged and has allowed for faster and...more
The Treasury Department and the IRS published proposed regulations yesterday on the Base Erosion and Anti-Abuse Tax (BEAT) that was enacted by the Tax Cuts and Jobs Act of 2017. ...more
Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more
Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used...more