News & Analysis as of

U.S. Treasury Reporting Requirements Corporate Taxes

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

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

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

Foodman CPAs & Advisors

2021 “Green Book” Introduces Comprehensive Financial Account Reporting

The “Green Book” is a US Treasury Department document that presents detailed explanations of an Administration’s revenue proposals in support of a President’s annual budget request.  On May 28, 2021, the Biden administration...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 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 December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 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 September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Eversheds Sutherland (US) LLP

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

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