On Friday, April 10, 2020, the IRS released Rev. Proc. 2020-22 providing procedural guidance to taxpayers wishing to implement changes made by the CARES Act to the section 163(j) business interest deduction limitation. Under...more
On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more
9/25/2019
/ Bonus Depreciation ,
Commercial Leases ,
Depreciation ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Proposed Legislation ,
Public Utility ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
On September 6, 2019, the Internal Revenue Service (Service) issued Rev. Proc. 2019-37, which grants advance consent to taxpayers seeking to change a method of accounting to comply with the new proposed regulations under...more
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more
On July 11, 2019, the Internal Revenue Service (Service) and Department of Treasury (Treasury) issued final regulations to remove Treas. Reg. § 1.451-5, which allowed taxpayers to delay reporting income with respect to...more
On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more
On November 29, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-60, which provides automatic accounting method change procedures for taxpayers seeking to comply with section 451(b), relating to the timing of...more
12/11/2018
/ Accrual Method ,
Audited Financial Statements ,
Corporate Taxes ,
Financial Accounting ,
Financial Statements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Reform
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more
On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes...more
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more
On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the “transition tax”). Section 965...more
On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more
On May 10, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-29, 2018-21 I.R.B. 1, which provides automatic accounting method change procedures for taxpayers seeking to align methods of income recognition for...more
On May 10, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-31, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev. Proc. 2017-30, the list...more
On April 12, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-35 (Notice) that provides transitional guidance relating to advance payments under Rev. Proc. 2004-34. Despite the...more
The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more
4/10/2018
/ Accounting Methods ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Income Taxes ,
International Tax Issues ,
IRS ,
Shareholders ,
Subpart F ,
Tax Rates
On March 27, 2018, the Internal Revenue Service (IRS) issued Notice 2018-23 (the Notice), providing transitional guidance for parties to suits and agreements covered by sections 162(f) and 6050X of the Internal Revenue Code...more
New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new campaigns continue the IRS’s move to...more
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The announcement of these new campaigns reiterates LB&I’s efforts to focus...more
New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The five campaigns supplement the 13 initial...more
On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the TCJA), the most substantial overhaul of the Internal Revenue Code since 1986. The TCJA significantly changes how the US taxes individuals,...more
As noted in a previous Eversheds Sutherland Legal Alert, on November 2, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1) (the House Bill). An amended version of the House Bill (the Ways and...more
On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more
Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more