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Income Taxes › Proposed Regulation

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

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Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Cadwalader, Wickersham & Taft LLP

Partnerships Gain CAMT Alternative

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On July 29, the IRS issued interim guidance intended to reduce the compliance burdens associated with applying the corporate alternative minimum tax (“CAMT”) to partnerships.  In so doing, they announced their intention to...more

Alston & Bird

Asset Managers with California Investors Could Face New State and Local Taxes

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Our State & Local Tax Team breaks down proposals from both California and San Francisco that would use investors’ location to decide whether to tax out-of-state asset managers....more

McCarter & English, LLP

Proposed Corporation Business Tax Regulations, Proposing Sweeping Changes, Published in ‘New Jersey Register’

McCarter & English, LLP on

On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...more

Goodwin

Internal Revenue Code Section 162(m): Proposed Regulations

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On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more

Eversheds Sutherland (US) LLP

California’s proposed market sourcing reg raises questions

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The California Franchise Tax Board (FTB) has proposed amendments to its regulations that govern how sales of services and intangibles are sourced for income tax purposes. The changes to this income tax apportionment...more

Cooley LLP

Treasury Department Issues Final and Proposed Rules on Cloud Transactions, Other Digital Content

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On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more

Groom Law Group, Chartered

IRS Issues Proposed Regulations Implementing Changes to Code Section 162(m)

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On January 14, 2025, the Internal Revenue Service (“IRS”) and the Department of Treasury issued proposed regulations under Internal Revenue Code (“Code”) section 162(m), which limits the deductibility of certain employee...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

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On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

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On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Mayer Brown

National Congress Approves Additional CSLL to Adapt to OECD Globe Rules and New Provisions Related to Brazilian Worldwide Taxation...

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I – ADDITIONAL CSLL - Following the House of Representatives’ approval just one day before, the Brazilian Federal Senate approved, on December 18, 2024, Bill of Law No. 3,817/2024 (the “bill”), which introduces an...more

McDermott Will & Schulte

Five Key Takeaways From the Proposed PTEP Regulations

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Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

Vinson & Elkins LLP

CAMT Claus Is Staying In Town?

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Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice. However, taxpayers and their advisors wishing for a repeal of the corporate alternative minimum tax in 2025...more

Eversheds Sutherland (US) LLP

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such...

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On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more

Cadwalader, Wickersham & Taft LLP

Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations

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On September 13, 2024, in the Federal Register, the Treasury and IRS published proposed regulations implementing the corporate alternative minimum tax (“CAMT”).  Its 182 pages (including 62 pages of preamble) describe a...more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managers

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On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

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The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

McDermott Will & Schulte

Weekly IRS Roundup July 15 – July 19, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15, 2024 – July 19, 2024. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

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On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

Freeman Law

Proposed Regulations on Loans of Cash and Property from Foreign Trusts

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On May 8, 2024, the Treasury Department issued proposed regulations regarding the classification, taxation, and reporting of foreign trusts. The proposed regulations were issued for sections 643(i), 679, 6039F, 6048, and 6677...more

Proskauer Rose LLP

Wealth Management Update - June 2024

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June 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

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The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

McDermott Will & Schulte

Weekly IRS Roundup May 20 – May 24, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

Katten Muchin Rosenman LLP

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations for Some US Taxpayers

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It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more

McDermott Will & Schulte

Weekly IRS Roundup April 8 – April 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

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