News & Analysis as of

Internal Revenue Service Taxation Corporate Taxes

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.  
Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #3

Speaker Johnson Kicks Off Discussions for Reconciliation 2.0: House Republicans are laying the groundwork for a second reconciliation bill this fall that aims in part to revive key provisions excluded from the One, Big,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #2

Passthrough Deduction Eyed for Bigger Boost in Future Bill: House Republicans are weighing the possibility of a second major tax package following the recent enactment of their One, Big, Beautiful Bill Act (OBBBA, Public Law...more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...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

Hogan Lovells

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

Cadwalader, Wickersham & Taft LLP

New IRS Guidance Regarding Section 162(m)’s Deduction Limitation for Executive Compensation – Increased Complexity and Reduced...

The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more

Stinson - Corporate & Securities Law Blog

IRS Issues Guidance on Section 162(m)

As noted on our Benefits Notes blog, on August 21, 2018, the IRS issued its initial guidance on the amendments to Section 162(m) made by the Tax Cuts and Jobs Act, in the form of Notice 2018-68. The guidance is fairly limited...more

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