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Tax Planning Proposed Regulation Income Taxes

McCarter & English, LLP

Proposed Corporation Business Tax Regulations, Proposing Sweeping Changes, Published in ‘New Jersey Register’

On February 18, the New Jersey Division of Taxation published proposed corporation business tax (CBT) regulations that incorporate changes associated with 2023 reform legislation, as well as additional changes intended to...more

Goodwin

Internal Revenue Code Section 162(m): Proposed Regulations

Goodwin on

On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more

Eversheds Sutherland (US) LLP

California’s proposed market sourcing reg raises questions

The California Franchise Tax Board (FTB) has proposed amendments to its regulations that govern how sales of services and intangibles are sourced for income tax purposes. The changes to this income tax apportionment...more

Cooley LLP

Treasury Department Issues Final and Proposed Rules on Cloud Transactions, Other Digital Content

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On January 10, 2025, the US Department of the Treasury and IRS released final and proposed regulations that provide tax guidance for the digital economy....more

Groom Law Group, Chartered

IRS Issues Proposed Regulations Implementing Changes to Code Section 162(m)

On January 14, 2025, the Internal Revenue Service (“IRS”) and the Department of Treasury issued proposed regulations under Internal Revenue Code (“Code”) section 162(m), which limits the deductibility of certain employee...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

Cadwalader, Wickersham & Taft LLP

Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations

On September 13, 2024, in the Federal Register, the Treasury and IRS published proposed regulations implementing the corporate alternative minimum tax (“CAMT”).  Its 182 pages (including 62 pages of preamble) describe a...more

McDermott Will & Schulte

Weekly IRS Roundup May 20 – May 24, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20, 2024 – May 24, 2024. ...more

McDermott Will & Schulte

Weekly IRS Roundup April 1 – April 5, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024....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

McDermott Will & Schulte

Weekly IRS Roundup February 19 – February 23, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 19, 2024 – February 23, 2024. February 20, 2024: The IRS published Announcement 2024-12, which...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

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

McDermott Will & Schulte

Weekly IRS Roundup December 25 – December 29, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 25, 2023 – December 29, 2023...more

McDermott Will & Schulte

Weekly IRS Roundup December 11 – December 15, 2023

McDermott Will & Schulte on

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

McDermott Will & Schulte

Weekly IRS Roundup November 20 – November 24, 2023

McDermott Will & Schulte on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 20, 2023 – November 24, 2023....more

McDermott Will & Schulte

Weekly IRS Roundup November 13 – November 17, 2023

McDermott Will & Schulte on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 13, 2023 – November 17, 2023. ...more

McDermott Will & Schulte

Weekly IRS Roundup August 14 – August 18, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 14, 2023 – August 18, 2023...more

Cadwalader, Wickersham & Taft LLP

Playing the Waiting Game on Crypto Tax Reporting

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

McDermott Will & Schulte

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Freeman Law

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

Freeman Law on

Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning - On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more

Freeman Law

Treasury Issues Proposed Regulations on IRS Appeals Procedures

Freeman Law on

Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more

Stark & Stark

[Webinar] The Administration’s 2022 Proposed Estate and Gift Tax Changes - June 21st, 6:00 pm - 6:45 pm ET

Stark & Stark on

Join Robert F. Morris, Esq., to discuss some important components of the Administration’s proposed changes to Federal Estate and Gift Taxes. The discussion will include how these changes may impact you and your estate plan....more

Stark & Stark

[Webinar] The Administration’s 2022 Proposed Estate and Gift Tax Changes - June 21st, 12:00 pm - 1:45 pm ET

Stark & Stark on

Join Robert F. Morris, Esq., to discuss some important components of the Administration’s proposed changes to Federal Estate and Gift Taxes. The discussion will include how these changes may impact you and your estate plan....more

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