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Treasury Regulations U.S. Treasury

Womble Bond Dickinson

Micro-captive Insurance Reportable Transactions and the Reporting Requirements

Womble Bond Dickinson on

Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Treasury Proposes Sweeping Changes Narrowing a Key Exception from U.S. Taxation for U.S. Real Estate Investments Made by...

Key Points - Recently proposed regulations would significantly curtail the ability for private fund sponsors and non-U.S. investors to use a so-called D-REIT to facilitate a tax-efficient exit from U.S. real property...more

Verrill

The How and When of Separations from Service Under Section 409A

Verrill on

Readers who regularly work with deferred compensation plans will know that Section 409A of the Internal Revenue Code (“Section 409A”) prescribes six events or times at which deferred compensation may be distributed to...more

Freeman Law

Treasury Regulation § 301.7602-1 and Nongovernment Contractors

Freeman Law on

The IRS and Treasury Department issued a new and finalized version of Treasury Regulation § 301.7602-1. The regulations took effect on September 7, 2021, and shine a new light on nongovernment contractors’ participation in...more

Foley & Lardner LLP

Co-Investment Vehicles Under the Final Carried Interest Regulations

Foley & Lardner LLP on

As a result of final Treasury Regulations issued by the IRS under Section 1061, fund sponsors should consider investing capital through a commingled fund with other investors as opposed to using its own investment vehicle to...more

Jones Day

UAE Removed From U.S. Treasury's Boycotting Countries List

Jones Day on

The U.S. Department of the Treasury has removed the United Arab Emirates from its latest "List of Countries Requiring Cooperation With an International Boycott," easing certain tax reporting requirements. On April 8, 2021,...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Removes UAE from List of Countries Requiring Cooperation with an International Boycott

Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more

Moore & Van Allen PLLC

New Treasury Department Regulations Modify Mandatory Filing Requirements for Critical Technology Businesses

Moore & Van Allen PLLC on

The U.S. Department of the Treasury (“Treasury”) recently published a proposed rule that would modify the mandatory filing requirements in place throughout the pilot program for certain foreign investment transactions subject...more

McDermott Will & Emery

Treasury and the IRS Release Final Foreign Tax Credit Regulations

McDermott Will & Emery on

Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

A&O Shearman

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

A&O Shearman on

On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

McDermott Will & Emery

Weekly IRS Roundup July 8 – 12, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8 – 12, 2019. July 9, 2019: The IRS updated its frequently asked questions page for the...more

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