News & Analysis as of

Internal Revenue Service Final Rules New Regulations

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Orrick, Herrington & Sutcliffe LLP

Treasury revokes final rule following Congress’s repeal

On July 11, the IRS published a rule in the Federal Register revoking a rule the IRS had issued in December 2024 after the rule had been repealed by Congress under the Congressional Review Act. The final rule, “Gross Proceeds...more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

Mayer Brown on

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

ArentFox Schiff

FinCEN Issues Final Rules & Regulations for CTA

ArentFox Schiff on

Knowing who owns legal entities is essential to stopping terrorism, money laundering, and other sophisticated criminal enterprises. For entities formed in the United States there has never been a requirement to disclose...more

Herbert Smith Freehills Kramer

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Emery on

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

Ballard Spahr LLP

U.S. Treasury Changes 401(k) and 403(b) Hardship Withdrawal Rules

Ballard Spahr LLP on

The U. S. Department of the Treasury recently issued final regulations governing hardship distributions from 401(k) and 403(b) retirement savings plans....more

Proskauer - Tax Talks

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate...

Proskauer - Tax Talks on

Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders. ...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

McCarter & English, LLP

Final Issue Price Regulations Present Municipal Industry Challenges (and 180 Days to Overcome Them)

McCarter & English, LLP on

The Internal Revenue Service promulgated final Issue Price Regulations under Section 148 of the Internal Revenue Code of 1986, as amended, that were published in the Federal Register on December 9, 2016. The new regulations...more

Bracewell LLP

Final Issue Price Regulations Significantly Change Current Rules

Bracewell LLP on

On December 9, 2016, the IRS released final Treasury Regulations (the “Final Regulations”) relating to the “issue price” of tax-exempt bonds for purposes of arbitrage investment restrictions. Although, on balance, an...more

McDermott Will & Emery

Treasury Finalizes Regulations on the Varying Interests Rule Under Section 706

McDermott Will & Emery on

On August 3, 2015, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations under Section 706(d), providing rules for determining the partners’ distributive shares of...more

BakerHostetler

IRS Issues Final Regulations on Requirements for Charitable Hospital Organizations

BakerHostetler on

On December 29, 2014, Final Regulations providing guidance regarding the requirements for charitable hospital organizations were issued by the Internal Revenue Service (IRS). The ACA, enacted March 23, 2010, added new...more

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