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Tax Planning New Guidance Revenue Procedures

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

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

Ballard Spahr LLP

IRS Releases Guidance on the Transition From LIBOR

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The IRS recently released helpful guidance in Revenue Procedure 2020-44 to assist the market’s transition from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (IBORs) to alternative reference...more

Morgan Lewis

IRS Issues New Group Ruling Guidance in Proposed Form

Morgan Lewis on

The Internal Revenue Service (IRS) issued a proposed revenue procedure on group rulings that includes significant changes to the existing procedures under Rev. Proc. 80-27 and substantially restricts eligibility for group...more

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

Foley & Lardner LLP on

On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

Holland & Hart LLP

IRS Publishes Guidance on the Carbon Capture Tax Credit

Holland & Hart LLP on

On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Anticipated Guidance on Section 45Q Carbon Capture Credits

Further clarity could help unlock much needed investment for a significant number of delayed projects. - After a two-year delay, the IRS finally issues highly anticipated guidance regarding the carbon capture tax credit...more

Eversheds Sutherland (US) LLP

Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit

In this Bottom Line videocast, Susan Lafferty and Amish Shah discuss: Section 45Q Carbon Capture and Sequestration credit. Beginning of Construction Guidance—Notice 2020-12. Partnership Allocation Guidance—Revenue Procedure...more

Akin Gump Strauss Hauer & Feld LLP

Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors

The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more

McDermott Will & Schulte

Weekly IRS Roundup December 16 – 20, 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 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

McDermott Will & Schulte

Weekly IRS Roundup November 4 – 8, 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 November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International...more

McDermott Will & Schulte

Weekly IRS Roundup October 7 – October 11, 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 October 7 – October 11, 2019. October 7, 2019: The IRS announced that taxpayers who requested...more

McDermott Will & Schulte

Weekly IRS Roundup April 29 – May 3, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29 – May 3, 2019. April 29, 2019: The IRS issued a news release urging taxpayers who had...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

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