Tax Reform, U.S. Treasury, New Guidance

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

Cadwalader, Wickersham & Taft LLP on 3/25/2025

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

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on 7/9/2024

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

Navigating the new elective safe harbor for the Domestic Content Bonus Tax Credit

A&O Shearman on 6/3/2024

The U.S. Treasury Department and the Internal Revenue Service have issued a new safe harbor that will make it easier for U.S. solar, onshore wind and battery storage projects with U.S.-sourced components to qualify for...more

First Round of Opportunity Zone Guidance Proposed by Treasury Department - Economic Development News

Bradley Arant Boult Cummings LLP on 10/24/2018

The Tax Cuts and Jobs Act created the Opportunity Zone program, which was designed to encourage investment in economically distressed communities by allowing taxpayers to defer and potentially exclude certain portions of...more

New Guidance on Opportunity Zones: Incentives for Investments in Low-Income Communities

Holland & Knight LLP on 10/23/2018

• Holland & Knight previously published a three-part series describing the powerful new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." •...more

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

Latham & Watkins LLP on 7/26/2018

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more