News & Analysis as of

New Guidance U.S. Treasury Corporate Taxes

McDermott Will & Schulte

IRS roundup: July 12 – July 29, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025. July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for...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

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Eversheds Sutherland (US) LLP

Charting a course: Guidance issued to help navigate potential issues for insurance industry with the corporate alternative minimum...

On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more

Latham & Watkins LLP

Treasury and IRS Issue Initial Guidance on Stock Buyback Tax and Corporate Minimum Tax

Latham & Watkins LLP on

New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more

Foley Hoag LLP

Update: April 15th Federal Income Tax Return Filing and Payment Deadlines Postponed to July 15th

Foley Hoag LLP on

The IRS and Treasury issued new guidance that supersedes earlier guidance relating to the postponement of the April 15, 2020 tax deadline due to the COVID-19 pandemic. On Friday, the IRS and Treasury announced that both the...more

McAfee & Taft

Oklahoma income tax filing dates delayed due to COVID-19

McAfee & Taft on

The day after the Oklahoma Tax Commission followed the previous guidance issued by the Internal Revenue Service to allow taxpayers to defer income tax payments but not filing requirements, U.S. Treasury Secretary Steven...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Permissibility of State Legislation to Circumvent SALT Deduction Cap

On Aug. 23, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under Section 170 of the Internal Revenue Code (Code) addressing the federal income tax treatment...more

Eversheds Sutherland (US) LLP

Think twice before deducting success-based fees - new Chief Counsel Advice denies deduction of success-based fee due to lack of...

On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more

Latham & Watkins LLP

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

Latham & Watkins LLP on

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

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