News & Analysis as of

Regulatory Requirements Internal Revenue Service U.S. Treasury

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Cooley LLP

Congress Repeals Digital Asset Regulations Applicable to Decentralized Finance Platforms

Cooley LLP on

In a January 27 client alert, we discussed final regulations issued on December 30, 2024, covering tax reporting requirements applicable to certain decentralized finance (DeFi) platforms operating as noncustodial brokers of...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...more

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Foley & Lardner LLP

Mandatory Roth Catch-up: More than Meets the Eye

Foley & Lardner LLP on

In January, the Department of the Treasury (“Treasury”) and Internal Revenue Service (IRS) issued proposed regulations on the catch-up contribution provisions under the SECURE 2.0 Act of 2022 (“SECURE 2.0”). While the...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

McDermott Will & Emery on

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Vedder Price

Regulations Requiring DeFi Platforms to Report Tax Information Nullified by Congress

Vedder Price on

On March 11, 2025, under the auspices of the Congressional Review Act (CRA), the U.S. House of Representatives approved a joint resolution (H.J. Res. 25) officially disapproving of recently finalized regulations that would...more

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Haynsworth Sinkler Boyd, P.A.

New Deadlines for FINCEN Compliance Issued

The Corporate Transparency Act (CTA) introduced substantial new reporting obligations for a wide array of corporate entities. Generally, any domestic entity formed by filing documents with a secretary of state or similar...more

Orrick, Herrington & Sutcliffe LLP

Final Regulations Released for the Clean Electricity Low-Income Communities Bonus Credit Program

The U.S. Department of the Treasury and the Internal Revenue Service have published final regulations concerning the low-income communities bonus credit program under Section 48E(h) of the Internal Revenue Code of 1986, as...more

Orrick, Herrington & Sutcliffe LLP

New IRS Guidance on Domestic Content Bonus Credit

The U.S. Department of the Treasury and the Internal Revenue Service have issued Notice 2025-08 (the “First Updated Elective Safe Harbor”), offering new guidance on the bonus credit for projects using domestically produced...more

Mayer Brown

Treasury Issues Final Regulations on Technology Neutral Clean Energy Projects

Mayer Brown on

On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

Morgan Lewis on

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Foodman CPAs & Advisors

FATCA Responsible Officer Certifications due 7/1/25

On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more

Holland & Knight LLP

Key Highlights of the Section 761 Final Regulations and Impact on Section 6417 Direct Payments

Holland & Knight LLP on

Under Section 6417 of the Code, as enacted by the Inflation Reduction Act (IRA), certain taxpayers that fall within the statutory definition of "applicable entities" are allowed to elect to receive a direct payment (i.e.,...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

Cadwalader, Wickersham & Taft LLP

Final Crypto Reporting Regulations for DeFi

On December 27, 2024, the Treasury and the IRS released final regulations (the “Final Regulations”) on reporting requirements for decentralized finance (“DeFi”) participants, accompanied by a press release, and Notice 2025-3,...more

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Dickinson Wright

If the Deadline for Self-Correcting Retirement Plan Errors Is Indefinite, Why Do I Have to Hurry?

Dickinson Wright on

Section 305 of SECURE 2.0 added rules for self-correcting a new category of retirement plan errors under the Employee Plans Compliance Resolution System (“ECPRS”). Specifically, Section 305 allows an “eligible inadvertent...more

Mayer Brown

Final Regulations on Taxpayers Eligible for Direct Pay Electing Out of Subchapter K

Mayer Brown on

On November 20, 2024, the US Department of the Treasury and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) to allow certain unincorporated organizations owned by specified “applicable...more

A&O Shearman

IRS creates a standardized Section 83(b) Election form

A&O Shearman on

On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620,1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” and such elections,...more

Eversheds Sutherland (US) LLP

Relief arrives for certain Model 1 FFIs that do not transmit US TINs to IRS

Notice 2023-11, issued in December 2023, provided limited relief to certain foreign financial institutions (FFIs) that were not fully in compliance with the terms of their Model 1 FATCA Intergovernmental Agreement (IGA)....more

McDermott Will & Emery

Semiconductor Industry Receives Long-Awaited Tax Credit Guidance From Treasury

McDermott Will & Emery on

On October 22, 2024, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited regulations implementing the advanced manufacturing investment credit under Sections 48D and 50...more

47 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide