News & Analysis as of

Proposed Regulation Comment Period Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

Comments Would Limit Circular 230 Proposed Regulations

On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations Under Section 30C

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Holland & Knight LLP

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

Holland & Knight LLP on

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Akin Gump Strauss Hauer & Feld LLP

Proposed Clean Hydrogen Guidance: Limitations on Credit Availability for Green Hydrogen Projects and Paths Forward

Guidance recently issued by the Department of the Treasury and the Internal Revenue Service (IRS) in proposed regulations (REG-117631-23) will (if held to be final) have a significant impact on green hydrogen projects in the...more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

Holland & Knight LLP on

The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

McDermott Will & Emery

Weekly IRS Roundup December 11 – December 15, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 11, 2023 – December 15, 2023. ...more

A&O Shearman

Treasury’s Proposed Regulations on Energy Property and the Energy Investment Tax Credit

A&O Shearman on

Among other things, the proposed regulations would: Below is a more detailed summary of the key provisions in the proposed regulations as well as our initial observations. The IRS will collect comments until January 22, 2024,...more

Holland & Knight LLP

Treasury Department, IRS Release Foreign Entity of Concern Proposed Regulations

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more

Groom Law Group, Chartered

Final Regulations Update Pension Plan Mortality Tables and Proposed Regulations Address COVID Impact on Substitute Tables

The IRS recently published final regulations regarding new mortality tables to be used for most qualified defined benefit plans. 88 Fed. Reg. 72,357 (Oct. 20, 2023). The new tables are effective for plan years starting in...more

Foodman CPAs & Advisors

Regulaciones Propuestas Para Activos Digitales Del IRS

Foodman CPAs & Advisors on

El 29/08/23, el IRS emitió un Aviso de Reglamentación Propuesta y un Aviso de Audiencia Pública para las regulaciones propuestas sobre los activos digitales. Las Regulaciones Propuestas de Activos Digitales del IRS abordan el...more

Foodman CPAs & Advisors

IRS Digital Assets Proposed Regulations

Foodman CPAs & Advisors on

On 8/29/23, the IRS issued a Notice of Proposed Rulemaking and Notice of Public Hearing for Digital Assets Proposed Regulations. The IRS Digital Assets Proposed Regulations address information reporting, the determination...more

Jones Day

Proposed IRS Regulations on Tax Credits for Renewable-Energy Investments Include Wage and Apprenticeship Requirements

Jones Day on

In Short - The Background: The Inflation Reduction Act provides for robust tax incentives on qualifying renewable-energy construction projects. In order to claim the full amount of such tax credits on qualifying projects,...more

Morgan Lewis

IRS Releases Proposed Digital Asset Regulations

Morgan Lewis on

The Internal Revenue Service (IRS) recently released proposed regulations regarding broker reporting for digital assets, including expansions of and additions to certain definitions, rules, and requirements. The IRS seeks...more

Paul Hastings LLP

IRS Issues Proposed Regulations for Digital Asset Reporting

Paul Hastings LLP on

The Internal Revenue Service and Treasury Department have issued long-awaited Proposed Regulations for parties that will be required to report transactions involving digital assets. These newly identified parties will need to...more

McDermott Will & Emery

Proposed Regulations From the IRS Outline Reporting Requirements for Cryptocurrency “Brokers”

McDermott Will & Emery on

On August 29, 2023, the Internal Revenue Service (IRS) published new proposed regulations on tax reporting requirements for cryptocurrency brokers. The proposed regulations build on efforts to expand IRS regulation over...more

Sullivan & Worcester

Treasury and IRS Issue Proposed Regulations for Tax Reporting Requirements on Digital Asset Transactions

Sullivan & Worcester on

On August 29, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS”) published proposed regulations that, if finalized, would require brokers (including digital asset trading platforms, digital asset...more

Eversheds Sutherland (US) LLP

Directions regarding Direct Pay - Proposed Regulations Released on Elective Payment for Inflation Reduction Act Renewable Energy...

On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more

Groom Law Group, Chartered

Proposed Treasury Regulation on Constructing Yield Curve for Funding Purposes

On June 23, the Treasury published proposed regulations on the methodology for constructing the yield curve that underlies how present values are calculated for defined benefit plans (88 Fed Reg 41047).  The proposed...more

Troutman Pepper Locke

IRS Proposes Regulations on Using Forfeitures in Qualified Retirement Plans

Troutman Pepper Locke on

Introduction - On February 27, 2023, the Department of the Treasury (“Treasury”) and Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) relating to forfeitures in tax-qualified...more

BakerHostetler

Overview of Proposed Regulations Superfund Taxes

BakerHostetler on

On March 29, the IRS and U.S. Treasury Department (Treasury) published proposed regulations regarding the recently reinstated Superfund chemical taxes (Proposed Regulations) and set a May 28 deadline for comments. The...more

Holland & Knight LLP

Treasury Department Issues Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

Holland & Knight LLP on

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment in the United States. The credit is equal...more

Tucker Arensberg, P.C.

New IRS Program Could Change the Way Food & Beverage Industry Tips are Reported - But First...the IRS Wants to Hear From You

Tucker Arensberg, P.C. on

Get ready for a game-changer in tip reporting compliance! The Treasury Department and IRS have just announced the proposed launch of the Service Industry Tip Compliance Agreement (SITCA) program. SITCA is a voluntary...more

Holland & Knight LLP

Proposed Treasury Regulations Reverse Guidance on Domestically Controlled REITs

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more

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