News & Analysis as of

U.S. Treasury Taxation

McDonnell Boehnen Hulbert & Berghoff LLP

Death and Taxes Should not be Certainties for the Patent System

The Department of Commerce has floated a proposal to tax U.S. patent holdings as a means of reducing the national debt, as outlined in a recent Wall Street Journal article. It is a bad idea that reflects a troubling...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more

Rivkin Radler LLP

Taxes: An American Obsession?

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Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain. In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025 #2

The Senate Republicans continue to meet internally and with stakeholders regarding the provisions of a reconciliation package (H.R. 1). Senate Majority Leader John Thune (R-SD) made it clear that the Senate will make...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025

House Passes Reconciliation Package, with Senate Expected to Make Changes: On May 22, the House of Representatives passed H.R. 1, “The One, Big, Beautiful Bill Act,” legislation authorized under the FY 2025 concurrent budget...more

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

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The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

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In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

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On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

Seward & Kissel LLP

Should you call 911 about Section 899?

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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

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

McDermott Will & Emery on

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Cadwalader, Wickersham & Taft LLP

House Republicans to Large Endowments: “Ask Not What …”

Under the House’s current draft budget bill, which was released on May 15, 2025, the 1.4% excise tax on private universities’ net investment income would increase up to 21%, effectively negating one of the main benefits of...more

Ropes & Gray LLP

House Passes Tax Package with Several Carved-Back Provisions Relevant to Tax-Exempt Organizations

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On May 22, 2025 the House of Representatives passed its version of the “One Big Beautiful Bill Act” (the “BBB”). As described in our prior Alert, the proposed package includes several key provisions of particular importance...more

Williams Mullen

IRS Withdraws Reporting Requirements for Certain Basis-Shifting Transactions

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On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more

Fox Rothschild LLP

Trump and Congress Nullify IRS Reporting Rule for Digital Assets

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The federal rule that would have required crypto platforms to report users’ transactions to the IRS has officially been scrapped. President Trump signed a joint congressional resolution overturning the so-called DeFi...more

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

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The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Fox Rothschild LLP

President Names Yet Another Acting IRS Commissioner

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Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more

Bricker Graydon LLP

The Possible Repeal of the Tax Exemption of Municipal Bond Interest

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You may have heard recently about proposals for Congress to remove the exclusion from gross income of interest on state and local bonds, usually referred to as “repealing the tax exemption on municipal bonds.”  This issue...more

Alston & Bird

Can Trump Replace Income Tax with Tariffs?

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President Trump has suggested using tariffs to lower the Federal Government’s reliance on income taxes....more

Foodman CPAs & Advisors

FATCA Responsible Officer Certifications due 7/1/25

On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more

Cadwalader, Wickersham & Taft LLP

Final Crypto Reporting Regulations for DeFi

On December 27, 2024, the Treasury and the IRS released final regulations (the “Final Regulations”) on reporting requirements for decentralized finance (“DeFi”) participants, accompanied by a press release, and Notice 2025-3,...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Final Regulations Applicable for Front-End Service Providers Facilitating Digital Asset and...

On December 30, 2024, the Department of the Treasury (the Treasury) and the Internal Revenue Service (the IRS) published the final regulations (Final DeFi Regulations) relating primarily to persons who are front-end service...more

The Wagner Law Group

IRS Issues Final Regulations on Non-U.S. Tax Withholding Under Deferred Compensation Plans, IRAs and Commercial Annuities

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The Internal Revenue Service (“IRS”) and the Treasury Department on October 21, 2024, issued final regulations under Sections 3405(a) and 3405(b) of the Internal Revenue Code of 1986, as amended (“Code”). (The IRS had issued...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

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