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Internal Revenue Service Proposed Regulation U.S. Treasury

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.  
Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Davis Wright Tremaine LLP

New Guidance Issued on Mandatory and Optional Catch-Up Provisions Under SECURE 2.0

New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more

Kilpatrick

IRS Issues Proposed Regulations Regarding Mandatory Auto-Enrollment Under SECURE 2.0

Kilpatrick on

The IRS and Treasury Department recently issued proposed regulations addressing the mandatory automatic enrollment provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0). The proposed regulations generally adopt the...more

Goodwin

Internal Revenue Code Section 162(m): Proposed Regulations

Goodwin on

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

Patterson Belknap Webb & Tyler LLP

New Proposed Catch-Up Contribution Regulations Answer Many Questions

Background - Many defined contribution plans are designed to permit participants to take advantage of an increased employee contribution limit starting the year they turn 50....more

Cooley LLP

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

Cooley LLP on

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

Jones Day

New Guidance on the Commercial EV Tax Credit

Jones Day on

In one of their final sets of guidance under President Biden, the Department of Treasury and the IRS released proposed regulations for the tax credit under Section 45W, which is available for purchasing electric vehicles for...more

Groom Law Group, Chartered

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

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

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

Jones Day

Draft Guidance on the Section 45Z Clean Fuel Production Credit

Jones Day on

The Department of Treasury and the IRS have released Notices 2025-10 and 2025-11, outlining intended forthcoming proposed regulations for the Section 45Z clean fuel production credit introduced by the Inflation Reduction Act...more

Cadwalader, Wickersham & Taft LLP

IRS and Treasury Issue Proposed Regulations on Tax-Free Reorganizations, Spin-Offs

On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.  The IRS and...more

Groom Law Group, Chartered

IRS Issues Guidance on Mandatory Automatic Enrollment

On January 10, 2025, the Treasury Department and the IRS issued Proposed Regulations addressing one of SECURE 2.0’s signature requirements: that all newly established 401(k) plans and 403(b) plans with cash or deferred...more

Holland & Knight LLP

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

McDermott Will & Emery

Five Key Takeaways From the Proposed PTEP Regulations

McDermott Will & Emery on

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?

Vinson & Elkins LLP on

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

Foley & Lardner LLP

IRS Releases Final Regulations Under Section 48 of the Code

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) and Department of the Treasury last week released final regulations (the “Final Regulations”) relating to investment tax credits under Section 48 of the (the “ITC”) of the Internal Revenue...more

Mayer Brown

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

Mayer Brown on

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

A&O Shearman

Treasury and the IRS proposed regulations on previously taxed earnings and profits

A&O Shearman on

On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended...more

Bracewell LLP

Treasury and IRS Issue Final and Proposed Regulations Expanding Applicable Entities’ Ability to Elect Direct Pay in Connection...

Bracewell LLP on

On November 19, 2024, the Treasury Department and the Internal Revenue Service issued final regulations under Internal Revenue Code (Code) Section 761 (the Final Regulations) enabling certain entities to make a direct pay...more

McDermott Will & Emery

Proposed Disregarded Payment Loss Rules Create Traps for the Unwary

McDermott Will & Emery on

Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming. Under the...more

Vinson & Elkins LLP

CAMT Touch This: Treatment of Tax Credits, Direct Pay, and Transferability under the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Section 45X Advanced Manufacturing Production Credit

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added the Section 45X Advanced Manufacturing Production Credit (Section 45X) to the Internal Revenue Code of 1986, as amended. Section 45X provides a credit against federal income tax for...more

Paul Hastings LLP

Proposed Regulations on the Section 30C Alternative Fuel Vehicle Refueling Property Credit

Paul Hastings LLP on

The Section 30C Alternative Fuel Vehicle Refueling Property Credit (the “Section 30C Credit”) provides a credit against federal income tax for eligible costs of qualified alternative fuel vehicle refueling property. The...more

McDermott Will & Emery

Semiconductor Industry Receives Long-Awaited Tax Credit Guidance From Treasury

McDermott Will & Emery on

On October 22, 2024, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited regulations implementing the advanced manufacturing investment credit under Sections 48D and 50...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...

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

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