News & Analysis as of

U.S. Treasury Internal Revenue Service New Regulations

Orrick, Herrington & Sutcliffe LLP

Treasury revokes final rule following Congress’s repeal

On July 11, the IRS published a rule in the Federal Register revoking a rule the IRS had issued in December 2024 after the rule had been repealed by Congress under the Congressional Review Act. The final rule, “Gross Proceeds...more

Husch Blackwell LLP

New Executive Order Targets Wind and Solar Tax Credits

Husch Blackwell LLP on

On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...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

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

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

Troutman Pepper Locke on

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Jones Day

Final Regulations Expand Access to "Direct Pay" Elections for Energy Credits

Jones Day on

The U.S. Department of the Treasury and the Internal Revenue Service have issued final regulations allowing tax-exempt entities that are partners in clean energy projects to elect to receive energy tax credits in cash....more

McDermott Will & Schulte

IRS Issues Final Rules on Intangible Property Repatriations

McDermott Will & Schulte on

With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly...more

Eversheds Sutherland (US) LLP

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such...

On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more

Allen Barron, Inc.

The IRS Digital Asset Broker Reporting Requirements

Allen Barron, Inc. on

The IRS digital asset broker reporting requirements were finalized earlier this year and impact all digital asset (i.e., cryptocurrency and Non-Fungible Tokens or NFTs) transactions beginning January 1, 2025. What do...more

Troutman Pepper Locke

IRS Issues Final Regulations on Prevailing Wages and Registered Apprenticeship Requirements

Troutman Pepper Locke on

On June 18, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) released final regulations (Final Regulations) on the prevailing wage and apprenticeship requirements under Section 45(b)(7) (Prevailing...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

Mayer Brown

Final Guidance Issued on “Foreign Entity of Concern” Criteria

Mayer Brown on

On May 3, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9995) concerning the clean vehicle credit under Section 30D of the Internal Revenue Code...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Treasury, Internal Revenue Service Issue Final Regulations for Transfer of Energy Credits

On April 25, 2024, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations regarding the transfer of energy tax credits under the Inflation Reduction Act of 2022 (IRA)....more

Mayer Brown

US Treasury Releases Final Regulations Addressing Domestic Control Determinations Under FIRPTA

Mayer Brown on

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

BakerHostetler on

As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Foley & Lardner LLP

IRS Releases Final Direct Pay Regulations

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) and Department of the Treasury earlier this week released final regulations relating to direct cash payments for certain tax credits pursuant to Section 6417 of the Internal Revenue Code...more

ArentFox Schiff

IRS, Treasury Release Final Regulations Impacting Type I and Type III Supporting Organizations

ArentFox Schiff on

The Internal Revenue Service (IRS) and the US Department of the Treasury released final regulations on October 16 that address the changes enacted by the Pension Protection Act of 2006 (PPA). The regulations provide...more

Warner Norcross + Judd

Proposed Treasury Regulations Impose Hard Deadline and Requirements on Forfeitures in Defined Contribution Plans

Warner Norcross + Judd on

The U.S. Department of the Treasury has recently proposed new regulations that clarify when and for what purposes defined contribution plans — such as 401(k) plans — may use forfeitures. These regulations are proposed to...more

Fenwick & West LLP

IRS Delays Infrastructure Act's Broker Reporting Requirements

Fenwick & West LLP on

On December 23, 2022, the Internal Revenue Service (IRS) released Announcement 2023-2 in response to the new broker reporting rules that were part of the 2021 Infrastructure Investment and Jobs Act (the Infrastructure Act)....more

Cadwalader, Wickersham & Taft LLP

Treasury Holds Fast on Centralized Partnership Audits

On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more

Mintz - Public Finance Viewpoints

Treasury and IRS Release Final Tax Regulations for LIBOR Replacement Amendments

The lengthy saga of the transition to a post-LIBOR world reached a degree of finality on the tax side with the issuance by the Department of Treasury and Internal Revenue Service (IRS) of long-awaited final regulations (the...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Gould + Ratner LLP

IRS Finalizes Carried Interest Regulations

Gould + Ratner LLP on

The IRS and Treasury Department released final regulations on January 7, 2021, that govern the tax treatment of partnership and LLC interests related to services, so-called carried interests, a/k/a applicable partnership...more

Perkins Coie

Final Regulations Issued Regarding Section 45Q Tax Credits Carbon Oxide Sequestration

Perkins Coie on

The U.S. Department of the Treasury and the Internal Revenue Service on January 6, 2021, issued Treasury Decision 9944, providing final regulations relating to Section 45Q tax credits (Regulations). The Regulations provide...more

Bracewell LLP

IRS and Treasury Department Release Final Regulations Regarding Like-Kind Exchanges

Bracewell LLP on

On November 23, 2020, the IRS and Treasury Department released final regulations (the Final Regulations) under Section 1031 of the Internal Revenue Code of 1986, as amended (the Code). Prior to the Tax Cuts and Jobs Act of...more

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