News & Analysis as of

U.S. Treasury Tax Liability Tax Reform

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

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

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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

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

Proskauer - Tax Talks on

On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...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

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

Cadwalader, Wickersham & Taft LLP

IRS Hints at Revolution in Tax-Free Spin-Off Rules, Ruling Practice

Over the last three months, public statements by U.S. Treasury and Internal Revenue Service officials have suggested that they are in the process of significantly revising the rules governing tax-free spin-offs, split-offs...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

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Brownstein Hyatt Farber Schreck

IRS Releases Long-Awaited Spending Plan for $80 Billion in New Inflation Reduction Act Funding

On Thursday, April 6, the Treasury Department and Internal Revenue Service (IRS) issued their long-term Strategic Operating Plan (SOP), outlining how the IRS intends to spend $79.4 billion in funding provided by the Inflation...more

Littler

Treasury Department’s Greenbook Discusses Tax Treatment of On-Demand Pay

Littler on

The U.S. Department of the Treasury has released a document to explain the revenue proposals included in President Biden’s FY 2023 proposed Budget.  For the second consecutive year, the General Explanations of the...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

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Cadwalader, Wickersham & Taft LLP

President Biden’s Greenbook Provides Clarity on Digital Asset Taxation

The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals (the “Greenbook”), which elaborates on revenue proposals in President Joe Biden’s Fiscal Year 2023 Budget Proposal,...more

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