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U.S. Treasury Internal Revenue Code (IRC)

Saul Ewing LLP

New Provision Provides Above-The-Line Deduction for Overtime Pay

Saul Ewing LLP on

The new tax legislation, part of the "One Big Beautiful Bill", includes a temporary tax break for overtime pay, allowing eligible workers to deduct a portion of their overtime earnings from their federal income taxes. Section...more

Akin Gump Strauss Hauer & Feld LLP

Significant Cuts to IRA Clean Energy Tax Credits Included in Enacted Reconciliation Bill

President Trump signed the “One, Big, Beautiful Bill Act” (the “OBBB”) into law on July 4, 2025. Congress passed the legislation using the budget reconciliation process to avoid the 60-vote Senate filibuster. In addition to...more

McGuireWoods LLP

EO Directs Treasury to Issue Guidance on Beginning of Construction, BBB FEOC Restrictions

McGuireWoods LLP on

On July 7, 2025, President Donald Trump issued an executive order titled “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources.” The EO directs the U.S. Department of the Treasury to issue new...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

Foley & Lardner LLP

Executive Order on PTC and ITC Beginning of Construction

Foley & Lardner LLP on

President Trump yesterday issued an executive order, “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources” (the “Executive Order”), which could have a major impact on wind and solar energy...more

Foley & Lardner LLP

What’s the Future for Renewable Energy Tax Credits in Congress?

Foley & Lardner LLP on

The One Big Beautiful Bill Act (OBBB) has a significant impact on the renewable energy sector, particularly with changes in the phase-out schedules for wind and solar projects under Section 45Y and 48E, as well as the nuances...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

Seyfarth Shaw LLP on

On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

Procopio, Cory, Hargreaves & Savitch LLP

Elementos clave de la “One Big Beautiful Bill”

La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...more

Herbert Smith Freehills Kramer

Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...more

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

Paul Hastings LLP on

On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Seward & Kissel LLP

Should you call 911 about Section 899?

Seward & Kissel LLP on

On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Bergeson & Campbell, P.C.

BETO Updates 45ZCF-GREET Model to Incorporate New Methods of Alternative Fuel Production

On May 30, 2025, the U.S. Department of Energy (DOE) Bioenergy Technologies Office (BETO) announced that it “removed barriers to domestic bioenergy production by updating its 45ZCF-GREET modeling tool to account for new...more

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting Domestic and Multinational Businesses

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

Williams Mullen on

On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Cadwalader, Wickersham & Taft LLP

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

McDermott Will & Emery on

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Vedder Price

Regulations Requiring DeFi Platforms to Report Tax Information Nullified by Congress

Vedder Price on

On March 11, 2025, under the auspices of the Congressional Review Act (CRA), the U.S. House of Representatives approved a joint resolution (H.J. Res. 25) officially disapproving of recently finalized regulations that would...more

Davis Wright Tremaine LLP

New Guidance Issued on Mandatory and Optional Catch-Up Provisions Under SECURE 2.0

New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Vinson & Elkins LLP

Tax Law (and Controversy) Under the Trump Administration

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As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Morgan Lewis

Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

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