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House Enacts the Senate Legislative Text of the One Big Beautiful Bill Act

On July 3, 2025, the House approved the Senate’s legislative text (the “Senate Legislative Version”) for the budget reconciliation bill (H.R. 1, the “One Big Beautiful Bill Act”) without any changes. Thus, the final...more

US Senate Finance Committee Makes Changes to Proposed Section 899

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...more

IRS Releases Final Energy Property Regulations Under Section 48 Investment Tax Credit

On December 4, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations, TD 10015, (the “Final Regulations”), which provide guidance on the definition of energy...more

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

Final Guidance Issued on “Foreign Entity of Concern” Criteria

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

REITs’ Clean Energy Tax Credits Transfer Options Under IRA Clarified in Final Regulations

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations”) concerning the election to transfer certain tax credits...more

Final Regulations Issued on Direct-Pay Elections and Transfer of Tax Credits

On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations under section 6418”) concerning the election to transfer...more

US Treasury Releases Final Regulations Addressing Domestic Control Determinations Under FIRPTA

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more

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