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Tax Planning New Guidance

Mayer Brown

Recovery of VAT on DB Pension Scheme Investment Costs – New HMRC Policy

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HMRC has announced a new policy on the recovery by employers of VAT charged on investment services provided to their DB pension schemes. Until 18 June 2025, the extent to which an employer could recover any VAT paid on...more

Holland & Knight LLP

IRS Issues Updates for Energy Community Bonus Tax Credit

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The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...more

White & Case LLP

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

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On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

DLA Piper

Italian Tax Authority Provides Guidance on VAT Treatment of Personnel Secondment Arrangements

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Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

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On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Cadwalader, Wickersham & Taft LLP

New York State Bar Association Tax Section Proposes Withdrawal of Proposed Spin-Off Regulations

On March 17, the Tax Section of the New York State Bar Association (the “Tax Section”) released a report on the proposed regulations on corporate spin-offs and reorganizations that were issued in January. As we discussed...more

Perkins Coie

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

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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

McDermott Will & Schulte

Weekly IRS Roundup October 30 – November 3, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 30, 2023 – November 3, 2023. ...more

McDermott Will & Schulte

Weekly IRS Roundup October 16 – October 20, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 16, 2023 – October 20, 2023...more

McDermott Will & Schulte

Weekly IRS Roundup September 11 – September 15, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 11, 2023 – September 15, 2023...more

Cadwalader, Wickersham & Taft LLP

IRS Says Crypto Protocol Changes Are Not Taxable

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Mayer Brown

US Treasury Issues Proposed Regulations on Section 30D Clean Vehicle Credit

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Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more

Freeman Law

Section 501(c)(3) Dissected: IRS Issues Detailed Guidance on Exempt Purposes

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On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more

McDermott Will & Schulte

Weekly IRS Roundup January 30 – February 3, 2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 30, 2023 – February 3, 2023...more

Sheppard Mullin Richter & Hampton LLP

Inflation Reduction Act: Prevailing Wage and Apprenticeship Requirement FAQs and Key Takeaways from the Initial Guidance from the...

As previously discussed in our blog Inflation Reduction Act: Wage and Apprenticeship Requirements, the Inflation Reduction Act (the “IRA”) restructured the tax credit system associated with qualified clean energy projects...more

Littler

Treasury Department Issues Guidance on the Inflation Reduction Act’s Prevailing Wage and Apprenticeship Requirements

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On November 30, 2022, the U.S. Treasury Department published in the Federal Register its guidance on the Inflation Reduction Act’s (IRA) new prevailing wage and apprenticeship requirements. Taxpayers seeking to qualify for...more

Polsinelli

The IRS expands crypto guidance to include “NFTs” and other “Digital Assets,” ahead of the 2022 filing season

Polsinelli on

The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more

Littler

IRS Raises Standard Mileage Rate for July to December 2022

Littler on

On June 9, 2022, the Internal Revenue Service issued Announcement 2022-13, increasing the optional standard mileage rate for the final six months of 2022 from 58.5 cents per mile to 62.5 cents per mile.  The new rate will be...more

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Proskauer - Not for Profit/Exempt...

IRS Releases Guidance on Requirements for Limited Liability Companies to Qualify as Tax-Exempt Entities

On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more

Freeman Law

Like-Kind Exchanges of Cryptocurrency—Recent IRS Guidance

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In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more

Stinson LLP

Sales and Use Taxes: Kansas and Missouri Move to Impose Collection Obligations on Marketplace Facilitators

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Recent legislation has brought Kansas and Missouri up-to-date with the nation by instituting new tax collection requirements for out-of-state retailers lacking a physical presence in their state....more

Gould + Ratner LLP

IRS Issues Guidance for Claiming the Employee Retention Credit for the First Half of 2021

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This week, the IRS issued guidance for employers claiming the employee retention tax credit for the first two quarters of 2021. Background: Changes Under December 2020 Stimulus Plan - Detailed in a previous Gould &...more

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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Alabama: The Alabama Commissioner of Revenue has issued a series of orders. On March 18, 2020, the commissioner ordered that late payment penalties are waived for small retail businesses whose monthly retail sales during...more

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