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Regulatory Requirements › Proposed Regulation › Tax Planning

Cadwalader, Wickersham & Taft LLP

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

Cadwalader, Wickersham & Taft LLP on

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

Eversheds Sutherland (US) LLP

San Francisco’s proposed regulation imitates California’s proposed regulation

Eversheds Sutherland (US) LLP on

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more

Morgan Lewis - ML Benefits

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

Morgan Lewis - ML Benefits on

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

Troutman Pepper Locke

IRS Issues Proposed Regulations on the Expanded Definition of "Covered Employee" Under Code Section 162(m)

Troutman Pepper Locke on

On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

Falcon Rappaport & Berkman LLP on

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

Perkins Coie on

Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more

Troutman Pepper Locke

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper Locke on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

Herbert Smith Freehills Kramer on

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Herbert Smith Freehills Kramer

Treasury and the Service Propose Regulations on Cloud and Digital Content Transactions

Herbert Smith Freehills Kramer on

On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more

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