Legal Alert: Inflation Reduction Act imposes a nondeductible 1% excise tax on...
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock...
View ArticleLegal Alert: Signed, sealed, delivered – Biden signs Inflation Reduction Act...
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with...
View ArticleLegal Alert: Inflation Reduction Act of 2022 signed into law – A summary of...
The Inflation Reduction Act of 2022 (the Act) was signed into law on August 16, 2022, and includes about $370 billon for American energy security and climate change. Those changes include very...
View ArticleLegal Alert: Inflation Reduction Act of 2022 – The energy tax provisions you...
The Inflation Reduction Act of 2022 (the Act) runs 725 pages and includes numerous energy tax provisions aimed at enhancing US. energy security. The Act, if enacted, would extend and expand the...
View ArticleLegal Alert: Inflation Reduction Act targets carried interests
On July 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would...
View ArticleLegal Alert: Back from the dead – Corporate minimum tax resurfaces at...
On July 27, 2022, the Senate announced agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 (the IRA), the artist formerly known as the Build Back Better Act (the BBBA)....
View ArticleLegal Alert: A welcome clean energy surprise – Inflation Reduction Act...
In a surprising turn of events, late on July 27, 2022, Senators Manchin (D-WV) and Schumer (D-NY) released the Inflation Reduction Act of 2022. The Act, which runs 725 pages, includes numerous energy...
View ArticleLegal Alert: An incomplete picture: Democratic senators release “framework”...
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The...
View ArticleLegal Alert: Downsizing from a House to a Manchin: Federal and International...
As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made...
View ArticleLegal Alert: FY 2022 Green Book goes big for green energy
On May 28, 2021, Treasury released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, more commonly referred to as the Green Book. The issuance of the Green Book...
View ArticleState of play: A May methods update
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury...
View ArticleThe Made in America Tax Plan Webcast Series
This three-part series focused on President Biden’s Made in America Tax Plan and addressed changes to federal provisions, energy taxes and changes for companies with non-US operations.April 21 | An...
View ArticleWho in the world is Joe Manchin: International tax proposals vary under...
Just a few months after regulations were finalized, and as taxpayers were getting comfortable with the international tax provisions implemented by the 2017 Tax Cuts and Jobs Act (TCJA), proposals from...
View ArticleTreasury and IRS Release Final Regulations under Section 163(j) with respect...
On January 5th, the Department of the Treasury and the Internal Revenue Service released final regulations under section 163(j). Amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally...
View ArticleOMB Completes Its Review of Proposed Regulations under Section 163(j)
The Office of Management and Budget (OMB) has completed its review of proposed regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its...
View ArticleDistrict Court Holds Section 965 Constitutional
On November 19, the U.S. District Court for the Western District of Washington held that the transition tax under section 965 was constitutional. Section 965, enacted by the Tax Cuts and Jobs Act,...
View ArticleTreasury and IRS Release Final BEAT Regulations
On September 1, the Department of the Treasury and the Internal Revenue Service released final regulations under section 59A. Section 59A imposes a base erosion and anti-abuse tax (or BEAT), which...
View ArticleIRS Releases Final Regulations under Section 250
On July 9, the Internal Revenue Services issued final regulations under section 250. Section 250 provides a deduction for both foreign-derived intangible income (FDII) and global intangible low-taxed...
View ArticleOIRA Completes Review of Final Regulations under Section 250
On June 12, the Office of Information and Regulatory Affairs (OIRA) completed its review of final regulations under section 250. Section 250 generally allows a domestic corporation a deduction for its...
View ArticleTreasury and IRS Release Final and Proposed Regulations under Section 163(j)
On July 28, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations under section 163(j). Amended by the Tax Cuts and Jobs Act (TCJA), section 163(j)...
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