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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

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Another CAMT crumble: IRS releases Notice 2024-10 addressing potential double counting from CFC dividends

On December 15, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Notice 2024-10 (Notice) addressing the potential double counting of income from controlled foreign corporations...more

Next Stop on the corporate minimum tax train: Issues which require guidance

Nearly two months ago, on August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with...more

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

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