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Internal Revenue Code (IRC) Taxation Tax Credits

Blank Rome LLP

One Big Beautiful Bill Act: Key Business, International, and Employment Tax Provisions

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The federal government enacted the One Big Beautiful Bill Act (the “Act”) on July 4, 2025. The Act extends and makes permanent certain tax provisions introduced in the Tax Cuts and Jobs Act (the “TCJA”) that were scheduled to...more

Cozen O'Connor

Tax Provisions Under One Big Beautiful Bill Affecting Real Estate Investment

Cozen O'Connor on

The enacted One Big Beautiful Bill (H.R.1, O3B) amends current tax law provisions and adds other provisions that affect real estate investments. This alert is intended to provide a summary of tax items under O3B of interest...more

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...more

Gould + Ratner LLP

What Employers Need to Know About the Employee Benefits Provisions in the OBBBA

Gould + Ratner LLP on

On July 4, the One Big Beautiful Bill Act (“OBBBA”) was enacted into law with President Donald Trump’s signature. Although the OBBBA’s tax and spending provisions tend to receive greater media attention, it also contains...more

Williams Mullen

The One Big Beautiful Bill Act Affecting Employee Benefits and Executive Compensation

Williams Mullen on

The One Big Beautiful Bill Act (the “Act”), signed into law on July 4, 2025, contains several provisions affecting employee benefits and executive compensation. Some of the key changes include the following...more

Hanson Bridgett

Timing is Everything for QSBS After the One Big Beautiful Bill Act

Hanson Bridgett on

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more

Foley & Lardner LLP

One Big Beautiful Bill Updates to Qualified Small Business Stock Rules under Section 1202

Foley & Lardner LLP on

As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

Venable LLP on

The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

Miller Canfield on

Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

McCarter & English, LLP

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

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

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Cozen O'Connor

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For

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PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Bradley Arant Boult Cummings LLP

Blazing Trails: Exploring ESOPs in the Cannabis Industry

The budding cannabis industry, despite its rapid growth and gradual acceptance in recent years, still faces a major sustainability challenge: Cannabis businesses cannot deduct most ordinary business expenses. Under Internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

McDermott Will & Schulte

Taxpayer Loses Claim for Research Credit

McDermott Will & Schulte on

In United States v. Grigsby, Docket No. 22-30764, the US Court of Appeals for the Fifth Circuit held that a refund claim based on claimed Internal Revenue Code (IRC) Section 41 credits was erroneous. Cajun Industries LLC, a...more

McDermott Will & Schulte

Weekly IRS Roundup June 20 – June 23, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the shortened week of June 20, 2023 – June 23, 2023. (June 19 is a federal holiday.)...more

Ballard Spahr LLP

IRS to Publish Final Utility Allowance Regulations for LIHTC Properties

Ballard Spahr LLP on

On Monday, the IRS will publish final utility allowance regulations for low-income housing tax credit (LIHTC) properties under Section 42 of the Internal Revenue Code (Code)....more

Littler

IRS Issues FAQs on Paid Family and Medical Leave Tax Credit

Littler on

The IRS has issued FAQs to provide guidance to employers relating to portions of the newly enacted Tax Cuts and Jobs Act of 2017 that created the Paid Family and Medical Leave Tax Credit....more

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