News & Analysis as of

U.S. Treasury Internal Revenue Code (IRC) Corporate Taxes

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

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

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

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

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

Cadwalader, Wickersham & Taft LLP

IRS Issues Final Partnership Basis Shifting Regulations

On January 10, 2025, the Treasury and IRS issued final regulations identifying certain partnership related party “basis shifting” transactions and substantially similar transactions as transactions of interest (TOIs), which...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

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

Fox Rothschild LLP on

President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...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

Cadwalader, Wickersham & Taft LLP

IRS and Treasury Issue Proposed Regulations on Tax-Free Reorganizations, Spin-Offs

On January 13, the U.S. Treasury and Internal Revenue Service released long-awaited proposed regulations governing the treatment of certain features of tax-free corporate spin-off and split-off transactions.  The IRS and...more

Morgan Lewis

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

Morgan Lewis on

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

Latham & Watkins LLP

The Corporate AMT’s Crypto Problem Poses Constitutional Hazards

Latham & Watkins LLP on

Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more

Holland & Knight LLP

Proposed Regulations Provide Clarity on Tax Treatment of Entities Wholly Owned by Tribal Governments

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS issued the Proposed Regulations on Oct. 9, 2024, providing long-awaited guidance on entities wholly owned by Tribal governments and organized or incorporated exclusively under the...more

McDermott Will & Emery

Five Key Takeaways From the Proposed PTEP Regulations

McDermott Will & Emery on

Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Cadwalader, Wickersham & Taft LLP

Notice 2023-7 Provides Initial Guidance Regarding the Corporate Alternative Minimum Tax

On December 27, 2022, Treasury issued Notice 2023-7, which provides guidance regarding the new Corporate Alternative Minimum Tax (“CAMT”) that taxpayers can rely on until Treasury publishes additional guidance. As mentioned...more

Holland & Knight LLP

Notice 2023-7: First Peek at Corporate AMT Guidance

Holland & Knight LLP on

As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more

McDermott Will & Emery

Weekly IRS Roundup September 20 – 24, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more

Eversheds Sutherland (US) LLP

Last minute addition to your summer reading list: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451...

On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

Holland & Knight LLP on

By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more

A&O Shearman

IRS and Treasury Issue Final Regulations Regarding Use of Consolidated Net Operating Losses

A&O Shearman on

On October 13, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the IRS) released final regulations (T.D. 9927) (the “Regulations”) under sections 1502 and 1503 of the Internal Revenue Code...more

73 Results
 / 
View per page
Page: of 3

"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