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Internal Revenue Code (IRC) Regulatory Agenda Income Taxes

DLA Piper

Senate Tax Bill: Key Points for the Investment Funds Industry

DLA Piper on

The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

Give Unto Caesar – Crypto?

On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more

Mayer Brown

Could 2025 Bring the Biggest Changes in US Tax Policy in History? Absolutely!

Mayer Brown on

2025 may well be the most consequential year in the history of US tax policy, at least since the establishment of the income tax through the 16th Amendment in 1913. While the US has a long history of enacting tax policies...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Mayer Brown

US Treasury to Propose Regulations on Energy Community Bonus Adders

Mayer Brown on

On April 4, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on qualifying for the energy community bonus credit under Sections...more

McDermott Will & Emery

Weekly IRS Roundup December 12 – December 16, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 12, 2022 – December 16, 2022...more

Freeman Law

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

Freeman Law on

Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning - On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

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On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Williams Mullen

The American Families Plan: Tax Implications for Real Estate Owners and Developers

Williams Mullen on

On April 28, 2021, President Biden announced a plan to expand benefits for lower- and middle-income Americans under his “American Families Plan” (the “Plan”). To pay for the Plan’s benefits, President Biden has proposed...more

Herbert Smith Freehills Kramer

Final Treasury Regulations Facilitate Foreign Subsidiary Credit Support

On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more

Holland & Hart - Employers' Lawyers

To Be or Not To Be … Subject to the New Section 83(i) Deferral Process - IRS Issues New Guidance

The Internal Revenue Service issued guidance on a tax law change that permits the deferral of income tax on equity awards in private companies. Section 83(i) of the Internal Revenue Code was included in the 2017 Tax Cuts and...more

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