News & Analysis as of

Proposed Regulation Disclosure Requirements Internal Revenue Service

Nutter McClennen & Fish LLP

IRS Issues New Proposed Regulations Under 162(m)

On January 14, 2025, the Internal Revenue Service (the “IRS”) issued new proposed regulations under section 162(m) of the Internal Revenue Code (the “Code”), supplementing regulations already in effect. Under section 162(m),...more

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Seward & Kissel LLP

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

Seward & Kissel LLP on

Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

Proskauer - Tax Talks

Treasury and IRS Announce New Attack on Partnership Basis-Shifting Structures and Establishment of “Passthrough Working Group” to...

Proskauer - Tax Talks on

On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

McDermott Will & Emery

Weekly IRS Roundup November 7 – November 11, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 7, 2022 – November 11, 2022....more

McDermott Will & Emery

Proposed Tax and Reporting for Digital Assets

McDermott Will & Emery on

On June 7, 2022, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced the highly anticipated Responsible Financial Innovation Act (the bill), which sets out to create the first complete regulatory and...more

Proskauer Rose LLP

ERISA Newsletter - Fourth Quarter 2018

Proskauer Rose LLP on

As we closed the door on 2018, we were met by two surprising decisions—one from a panel of the Second Circuit addressing employer stock drop litigation, and one from a federal district court in Texas declaring the entire...more

A&O Shearman

Focus on Tax Controversy and Litigation - Treasury and IRS Issue Proposed Regulations Imposing Documentation Requirements Under...

A&O Shearman on

In addition to the discussion of the recently proposed regulations which impose new documentation requirements under Section 385, this month’s issue features articles regarding the Circuit Court decision in Chemtech Royalty...more

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