News & Analysis as of

U.S. Treasury Regulatory Requirements Tax Planning

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Roth Mandate Mess: AICPA Asks for Clarity on SECURE 2.0 Catch-Up Contributions

When Congress passes sweeping retirement legislation, the details often come later—and those details usually come in the form of regulatory spaghetti that plan sponsors and administrators are left to untangle. Case in point:...more

Husch Blackwell LLP

Recent Developments from the OBBBA and EO 14315: Rush to Begin Construction and Pricing Uncertainty

Husch Blackwell LLP on

As we have discussed in recent articles and as has been well publicized, two recent actions out of Washington are significantly impacting the renewable energy industry. The recently enacted One, Big, Beautiful Bill Act...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

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...more

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

Mayer Brown on

On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Foley & Lardner LLP

Mandatory Roth Catch-up: More than Meets the Eye

Foley & Lardner LLP on

In January, the Department of the Treasury (“Treasury”) and Internal Revenue Service (IRS) issued proposed regulations on the catch-up contribution provisions under the SECURE 2.0 Act of 2022 (“SECURE 2.0”). While the...more

McDermott Will & Schulte

IRS Roundup February 17 – March 14, 2025

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

McDermott Will & Schulte

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

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

Proskauer - Tax Talks

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on

On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

Morgan Lewis on

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

Farrell Fritz, P.C.

IRS Proposes Modernized Rules for Tax Professionals Under Circular 230

Farrell Fritz, P.C. on

Last month, the Department of the Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in...more

Allen Barron, Inc.

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Perkins Coie

Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised Funds

Perkins Coie on

Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more

Herbert Smith Freehills Kramer

Final Treasury Regulations Clarify Business Interest Deduction Limitation

Background - On July 28, 2020, the Internal Revenue Service (IRS) issued final regulations (T.D. 9905) (the final regulations) concerning the limitation on the deductibility of business interest expense (BIE) under Section...more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

Herbert Smith Freehills Kramer

Treasury and the Service Propose Regulations on Cloud and Digital Content Transactions

On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more

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