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Reporting Requirements Internal Revenue Service Tax Cuts and Jobs Act

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

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One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of June 9, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

ArentFox Schiff

What Private Companies Need To Consider in 2024: Top 10 Legal Issues

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Private companies and their owners face ever-evolving challenges as the market sees new regulations, new deal trends, and new risks in 2024. Below are 10 issues that the owners and leaders of privately held companies should...more

Proskauer - Tax Talks

Section 1446(f) Final Regulations: Key Changes to Guidance on Non-Publicly Traded Partnership Interest Transfers by Non-U.S....

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On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more

Troutman Pepper Locke

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper Locke on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

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On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Jones Day

Deductibility of Fines and Penalties: New Guidance Leaves Key Questions Unanswered

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Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved. The U.S. Internal Revenue Service has released proposed regulations clarifying when fines, penalties, and...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

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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

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Holland & Knight LLP

New Guidance on Opportunity Zones: Highlights for Real Estate Owners and Developers

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• The U.S. Department of the Treasury issued a second tranche of proposed regulations to implement and clarify the new Opportunity Zone Tax Incentive. • These regulations expand previous guidance issued last October...more

Dickinson Wright

IRS Issues New Form for Reporting Non-deductible Fines and Penalties

Dickinson Wright on

Internal Revenue Code Section 162, as amended by the 2017 Tax Cuts and Jobs Act (TCJA), provides that no deduction is allowed for any amount paid to, or at the direction of, a governmental entity in relation to the violation...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, February 2019 #3

MEET THE MEMBERS - Now that everyone is familiar with the new House Ways and Means Committee members, it’s time to meet the newbies in the upper chamber’s tax writing committee: the Senate Finance Committee. Joining the...more

Foodman CPAs & Advisors

Swapping Virtual Currencies will trigger tax obligations under the Tax Cuts and Jobs Act

There are investors that have an interest in “exchanging or swapping” Virtual Currency (VC). Prior to the passage of the Tax Cut and Jobs Act (TCJA), VC investors could take the position that if they “exchanged or swapped”...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Foley & Lardner LLP

IRS Issues Transitional Guidance Regarding the New "Restitution" Tax Deduction That Affects False Claimes Act and Other Government...

Foley & Lardner LLP on

Effective immediately, a settlement agreement or a judgment with the government must set forth the specific amount of restitution, remediation of property, or monies paid to come into compliance with any law violated, for...more

McDermott Will & Emery

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

McDermott Will & Emery on

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

Sullivan & Worcester

Employment & Benefits News and Developments

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NEW TAX LAW MAKES CHANGES TO COMMUTING BENEFITS - ...The Tax Cuts and Jobs Act of 2017 (“TCJA”) generally eliminates employer deductions for commuter transportation and parking fringe benefits. This includes deductions...more

Foley & Lardner LLP

New Tax Law Changes Deductibility of Government Settlement Payments in False Claims Act, SEC, FINRA, and Other Types of Cases

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The new tax law changed the deductibility of settlements with government agencies in some circumstances thereby increasing the cost to companies to settle these cases. The deduction arose from the section in the Internal...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part III: IRC § 708 and the Partnership Termination Rules Have Changed

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BACKGROUND/PRIOR LAW - PartnershipUnder IRC § 708(a), a partnership is considered as a continuing entity for income tax purposes unless it is terminated. Given the proliferation of state law entities taxed as partnerships...more

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