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Reporting Requirements Tax Cuts and Jobs Act

Cozen O'Connor

Opportunity Zones Under the One Big Beautiful Bill Act

Cozen O'Connor on

On July 4, the One Big Beautiful Bill Act (OBBBA) became law and included some tweaks to the prior 2017 qualified opportunity zone (QOZ) tax legislation. The original QOZ rules, created by the Tax Cuts and Jobs Act of 2017,...more

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

Husch Blackwell LLP on

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the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Williams Mullen

Big, Beautiful Changes to the Qualified Opportunity Zone Program

Williams Mullen on

As anticipated, President Trump’s One Big Beautiful Bill Act (the “OBBBA”), which was signed into law on July 4, 2025, significantly amends Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the...more

Frost Brown Todd

There is No Sunset in the Land of OZ – Opportunity Zones Renewed by The One Big Beautiful Bill Act

Frost Brown Todd on

On July 4, 2025, President Trump signed H.R. 1—referred to as the “One Big Beautiful Bill Act” (OBBBA)—which permanently renewed and modified the federal Opportunity Zone tax incentive program that was set to expire at the...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

Eversheds Sutherland (US) LLP

Tax Bytes: Week of May 19, 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

ArentFox Schiff on

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....

Proskauer - Tax Talks on

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

Ballard Spahr LLP on

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

White & Case LLP on

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

Jones Day on

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 & Schulte

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Schulte 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

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 & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

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

McDermott Will & Schulte

[Event] 2019 Tax In The City®: Seattle - October 24th, Seattle, WA

We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more

Holland & Knight LLP

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

Holland & Knight LLP on

• 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

Bracewell LLP

New Requirements for Deducting Payments to Governmental Entities

Bracewell LLP on

Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity,...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part I)

In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified opportunity zones....more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

Proskauer - Tax Talks on

Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Opportune LLP

Outsourcing the Standardized Measure of Oil & Gas (SMOG) Calculation

Opportune LLP on

As many public oil and gas companies have made it through another year-end, it is a best practice to review what went right and what could be improved. Such questions to address include: Where did the reporting process not...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

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