News & Analysis as of

Proposed Regulation Tax Cuts and Jobs Act

Morgan Lewis - ML Benefits

IRS Proposes Regulations on Expanded Definition of Covered Employee Under Code Section 162m

Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more

Vinson & Elkins LLP

CAMT Claus Is Staying In Town?

Vinson & Elkins LLP on

Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice. However, taxpayers and their advisors wishing for a repeal of the corporate alternative minimum tax in 2025...more

Eversheds Sutherland (US) LLP

Short tax year savior: Rev. Proc. 2024-34

Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes - On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....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

Wilson Sonsini Goodrich & Rosati

IRS Issues Interim Guidance on Capitalization and Amortization of Research and Experimental Expenditures Under Section 174 of the...

On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Tucker Arensberg, P.C.

Gifting and Estate Tax in Period of Big Changes

Tucker Arensberg, P.C. on

​​​​​​​The Tax Cuts and Jobs Act of 2017 increased the federal estate and gift tax exclusion amount (sometimes called the “basic exclusion amount” or “BEA”) from $5 million to $10 million. (Those numbers are adjusted for...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act targets carried interests

On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more

Davis Wright Tremaine LLP

Not So Fast! IRS Releases Proposed Clawback Regulations

The IRS recently released proposed clawback regulations on the treatment of gifts that are complete at the time of transfer but are potentially included in the donor's gross estate at death. Such gifts will likely get the...more

Harris Beach Murtha PLLC

IRS Looks to Limit Estate Tax Break For Large Gifts in Tweak to Anti-Clawback Regulations

The Treasury Department issued proposed regulations on Tuesday, April 26, 2022 in follow up to the anti-clawback regulations published on November 26, 2019. The 2019 anti-clawback regulations were in response to the Tax Cuts...more

McDermott Will & Emery

Weekly IRS Roundup April 24 – April 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2022 – April 30, 2022... April 25, 2022: The IRS issued a news release, soliciting...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

McDermott Will & Emery

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Emery on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more

McDermott Will & Emery

Proposed Regulations Provide New Rules for Allocating and Apportioning Foreign Income Taxes Relating to Disregarded Payments

McDermott Will & Emery on

On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more

Bracewell LLP

IRS and Treasury Department Release Final Regulations Regarding Like-Kind Exchanges

Bracewell LLP on

On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of...more

Snell & Wilmer

2020 End of Year Plan Sponsor “To Do” List (Part 3) - Executive Compensation

Snell & Wilmer on

As 2020 comes to an end, we are happy to present our traditional End of Year Plan Sponsor “To Do” Lists. We are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered year-end health and...more

Ballard Spahr LLP

Treasury Announces Pass-Through Entities Will Not Be Subject to SALT Deduction Cap

Ballard Spahr LLP on

In a surprising—but taxpayer-friendly—development, Treasury announced in Notice 2020-75 (available here) that it will be issuing proposed regulations that allow partnerships and S corporations to deduct certain state and...more

Miles & Stockbridge P.C.

Treasury Releases Average Income Set-Aside Proposed Regulations

Miles & Stockbridge P.C. on

In 2017, the Tax Cuts and Jobs Act (the “Act”) added a third minimum set-aside option to qualify a project as a qualified low-income project pursuant to Code Section 42(g)(1)(C) - the Average Income Set-Aside. The Average...more

McGlinchey Stafford

No Partner/S-Corp Shareholder SALT Deduction Limit On Entity Income Taxes

McGlinchey Stafford on

The Internal Revenue Service has announced that it will be issuing proposed regulations clarifying that certain state or local income taxes imposed on and paid by a partnership and/or an S corporation will not be subject to...more

Troutman Pepper Locke

Structuring Sales of Investments by Funds After the Proposed Section 1061 Regulations

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Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more

Bracewell LLP

IRS and Treasury Department Release Last Set of Final Regulations on Bonus Depreciation

Bracewell LLP on

On September 21, 2020, the IRS and Treasury Department released the last set of final regulations (the 2020 Final Regulations) under the bonus depreciation rules of Section 168(k) of the Internal Revenue Code (the Code). ...more

McDermott Will & Emery

IRS Issues Final Regulations Concerning Withholding on Partnership Interest Transfers

McDermott Will & Emery on

The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more

McDermott Will & Emery

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

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On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

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