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Internal Revenue Service Proposed Rules 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.  
Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Cadwalader, Wickersham & Taft LLP

New York State Bar Association Tax Section Proposes Withdrawal of Proposed Spin-Off Regulations

On March 17, the Tax Section of the New York State Bar Association (the “Tax Section”) released a report on the proposed regulations on corporate spin-offs and reorganizations that were issued in January. As we discussed...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

Latham & Watkins LLP

Treasury Circulates Draft Regulations for Section 45Z Clean Fuel Production Credit

Latham & Watkins LLP on

A new tax credit is proposed to calculate a fuel’s emissions factor based on its full carbon life cycle of production. Notices 2025-10 and 2025-11 (Notices), released on January 10, 2025, outline the intention of the...more

Freeman Law

Treasury Issues Final Digital Asset Sourcing Regs and Proposed Cloud Transaction Sourcing Regs

Freeman Law on

On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions. Why is Source Important? While U.S. persons generally are...more

Eversheds Sutherland (US) LLP

Time to catch-up on your New Year’s regulations: IRS “super” and Roth guidance

On January 10, 2025, the Department of the Treasury and the Internal Revenue Service issued proposed regulations related to two new catch-up contribution provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0): (1) the...more

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...more

Foley Hoag LLP - Energy & Climate Counsel

A Boon for Biogas: Treasury’s Final Section 48 ITC Rules Resolve Key Concerns for Biogas and RNG Projects

On December 4, 2024, the Department of the Treasury finalized new rules governing the Section 48 Investment Tax Credit (“ITC”). The ITC applies to a broad range of clean energy projects, including biogas projects, which were...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

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Proposed Rules on New Tech-Neutral Clean Energy PTC and ITC

On May 29, 2024, the Internal Revenue Service (IRS) and the Department of Treasury issued proposed regulations (REG-119283-23) addressing the new technology neutral clean electricity production tax credit (PTC) in section 45Y...more

Seyfarth Shaw LLP

The Long Wait for the Long-Term Part-Time Guidance is Over

Seyfarth Shaw LLP on

Seyfarth Synopsis: It’s here for your post-Thanksgiving turkey hangover reading pleasure! The Department of Treasury and IRS released on Friday (in the middle of most people’s long holiday weekend) their proposed rules for...more

Husch Blackwell LLP

Notice of Proposed Rulemaking – ITC and Qualified Biogas Property

Husch Blackwell LLP on

On November 17, 2023, the U.S. Department of the Treasury issued a Notice of Proposed Rulemaking (the “NPRM”) with respect to Proposed Regulations under section 48 of the Internal Revenue Code of 1986 (the “Code”). The NPRM...more

Amundsen Davis LLC

Tax Incentives for Green Energy Projects Come With a Lot of Strings Attached

Amundsen Davis LLC on

On August 29, 2023, Clock on Grassthe U.S. Department of the Treasury and the Internal Revenue Service (IRS) released more guidance and proposed rules on key provisions in the Inflation Reduction Act (IRA) that requires...more

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Clean Energy Tax Credits/Inflation Reduction Act: American Clean Power Association Comments Addressing Proposed...

The Inflation Reduction Act (“IRA”) included provisions addressing the transferability of clean energy tax credits. Prior to the enactment of these IRA provisions, it was not possible to monetize federal tax credits...more

Allen Barron, Inc.

The US Treasury Department and IRS Have Released New Proposed Regulations on Sales and Exchanges of Digital Assets

Allen Barron, Inc. on

The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more

Cadwalader, Wickersham & Taft LLP

Is Treasury Tilting at Windmills with their Proposed Rules on Clean Energy Tax Credit Transfers?

Last August, the Inflation Reduction Act of 2022 (the “IRA”) introduced transferability provisions that will allow developers to sell clean energy tax credits.  On June 14, 2023, the IRS released proposed regulations and...more

Bracewell LLP

Treasury Department and IRS Issue Additional Guidance on the New Low-Income Communities Bonus Credit Program

Bracewell LLP on

The low-income communities bonus credit (the LIC Bonus), which was introduced by the Inflation Reduction Act of 2022 (the IRA), provides an enhanced tax credit for certain wind and solar facilities located in designated...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed Rules Regarding Direct Payment and Transferability of Certain Energy Tax Credits

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released two notices of proposed rulemaking regarding the direct payment of certain energy tax credits under Section 6417 of...more

Faegre Drinker Biddle & Reath LLP

Use of Forfeitures in Qualified Retirement Plans

On February 27, 2023, the IRS and the Department of Treasury published proposed regulations regarding the use of forfeitures in qualified retirement plans. If finalized, the proposed rule will be effective for plan years...more

White & Case LLP

US Treasury Department Publishes Proposed Guidance on Clean Vehicle Tax Credits

White & Case LLP on

On April 17, 2023, the US Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") published the Notice of Proposed Rulemaking for the Section 30D New Clean Vehicle Credit (the "Proposed Rules") to the...more

Groom Law Group, Chartered

IRS Proposed Regulation Addresses Rules Relating to Plan Forfeitures

Historically, the topic of forfeitures has raised many questions for qualified plan administrators- specifically, how and when they can be used.  But there has been little formal guidance from the Department of Treasury and...more

ArentFox Schiff

The US Inflation Reduction Act – The EV World is Watching - US trade rules to have significant impact on the law’s reach

ArentFox Schiff on

Enacted in August of 2022, the Inflation Reduction Act (IRA) was heralded by many as a landmark climate legislation in the United States. While the IRA’s tax credits for electric vehicles (EV) were among its most anticipated...more

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