News & Analysis as of

Tax Reform Proposed Regulation Corporate Taxes

Eversheds Sutherland (US) LLP

San Francisco’s proposed regulation imitates California’s proposed regulation

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more

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

Cooley LLP

Proposed Regulations Issued Under Internal Revenue Code § 162(m)

Cooley LLP on

Changes effective starting on January 1, 2027 - In the last few days preceding President Donald Trump’s inauguration, the IRS under the Biden administration proposed regulations to implement amendments to Internal Revenue...more

McDermott Will & Schulte

IRS Roundup January 13 – 17, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...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

Jones Day

New Proposed Regulations Address Spin-Off Transactions

Jones Day on

These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...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

McDermott Will & Schulte

Proposed Disregarded Payment Loss Rules Create Traps for the Unwary

McDermott Will & Schulte on

Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming. Under the...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...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

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

Holland & Knight LLP

Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?

Holland & Knight LLP on

En este episodio de "A Lo Legal En Par Minutos", nuestro abogado Edwin Cortés conversa con Gustavo Pardo, socio del área tributaria, sobre el impacto de la reforma tributaria de 2022 en Colombia. Nuestros abogados abordan...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

New York Formally Adopts Corporate Tax Reform Regulations

McDermott Will & Schulte on

On December 27, 2023, the New York State Department of Taxation and Finance (Department) adopted corporate tax reform regulations addressing New York’s corporate tax reform effective in 2015. The adopted regulations are...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

Eversheds Sutherland (US) LLP

New York moves to finalize corporate franchise tax regulations

On August 9, 2023, the New York State Department of Taxation and Finance (Department) submitted its draft corporate franchise tax regulations for publication in the State Register – a significant and necessary step in the...more

Cadwalader, Wickersham & Taft LLP

To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company...

U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more

Eversheds Sutherland (US) LLP

They have arrived: New York issues “final draft” corporate income tax apportionment regulations

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...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

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Troutman Pepper Locke

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper Locke on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

38 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide