News & Analysis as of

Comment Period Tax Liability Internal Revenue Code (IRC)

Eversheds Sutherland (US) LLP

IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

McDermott Will & Schulte

IRS Appeals Is Looking for Suggestions on Improving Conference Access

The Internal Revenue Service (IRS) has invited suggestions on improving conference options at the Independent Office of Appeals (IRS Appeals) for taxpayers and representatives who are not located near an IRS Appeals office...more

Littler

New Federal Tax Credits Require Compliance with New Prevailing Wage and Apprenticeship Mandates on Clean Energy Construction

Littler on

On August 16, 2022, President Biden signed into law the Inflation Reduction Act (IRA) of 2022. Among many other provisions, the IRA contains a new federal 30% tax credit for private construction, alteration or repair of...more

Snell & Wilmer

What’s in the Cloud? Proposed IRS Rules for Digital and Cloud Transactions

Snell & Wilmer on

The long wait is over – the Internal Revenue Service (IRS) has finally issued proposed regulations (the Cloud Regulations) addressing the tax treatment of cloud transactions. Until now, there was no guidance specifically...more

Holland & Knight LLP

Treasury Department, IRS Issue Proposed Rules on Tax Impact of Transition from Libor

Holland & Knight LLP on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more

McGuireWoods LLP

Treasury Proposes Guidance to Minimize Tax Consequences of LIBOR Phase-Out

McGuireWoods LLP on

The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of...more

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