News & Analysis as of

Proposed Regulation Internal Revenue Code (IRC) Tax Rates

McDermott Will & Emery

IRS Roundup May 15 – June 2, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more

Cadwalader, Wickersham & Taft LLP

Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules

The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Womble Bond Dickinson

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

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