The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more
Against the backdrop of rapidly evolving blockchain technology, the IRS has oftentimes been slow to update its related tax guidance, leaving participants in the blockchain ecosystem uncertain about their tax obligations....more
The Infrastructure Investment and Jobs Act, enacted on November 15, 2021, also known as the Bipartisan Infrastructure Law (the “BIL”), adds many important provisions regarding the development of the United States’...more
On January 6, 2021, the IRS issued final regulations relating to section 45Q. This is the fourth piece of guidance from the IRS relating to section 45Q, following IRS Notice 2020-12, Revenue Procedure 2020-12, the Proposed...more
1/29/2021
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Critical Infrastructure Sectors ,
Energy Projects ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
IRS ,
Production Tax Credit ,
Tax Credits ,
Tax Planning ,
Urban Planning & Development
Background. - While the fossil fuel industry continues to enjoy a number of tax incentives, a new generation of tax incentives were enacted in the early 2000s to promote the use of renewable energy. These include the...more
9/23/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Projects ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Real Estate Development ,
Renewable Energy ,
Tax Credits ,
Tax Planning
The IRS issued guidance in February 2020 for the Section 45Q tax credit program, which is aimed at supporting carbon capture and sequestration. The guidance reflected comments received by the IRS in response to Notice...more
On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more
12/21/2018
/ Banking Sector ,
FBAR ,
FinCEN ,
Foreign Financial Accounts ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
Voluntary Disclosure ,
White Collar Crimes
Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more
On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more
8/3/2018
/ Arms Length Transactions ,
Compensation & Benefits ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
IRS ,
Multinationals ,
Stock-Based Compensation ,
Tax Liability ,
Tax Planning ,
Technology Sector ,
Transfer Pricing
On May 25, 2018, the Council of the European Union formally adopted Council Directive 2018/822/EU on the reporting of "potentially aggressive" cross-border tax-planning arrangements....more
Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more
2/2/2018
/ Bonus Depreciation ,
Carried Interest Tax Rates ,
Compensation & Benefits ,
Corporate Taxes ,
EBITDA ,
Executive Compensation ,
Income Taxes ,
Net Operating Losses ,
New Legislation ,
Partnership Interests ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity Funds ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more
3/3/2017
/ AbbVie ,
Capital Losses ,
Inversion ,
IRS ,
Offshore Companies ,
Pharmaceutical Industry ,
Shareholder Votes ,
Stocks ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Termination Payments
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more