Legal Alert: Inflation Reduction Act imposes a nondeductible 1% excise tax on certain corporate stock buybacks
Posted on Aug 23, 2022 in Legal Alerts
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 (the Buyback Tax). The Buyback Tax is directly levied on repurchasing corporations, which means that corporations that currently have, or are considering, the adoption of stock buyback...
Legal Alert: Signed, sealed, delivered – Biden signs Inflation Reduction Act enacting “new” corporate minimum tax
Posted on Aug 17, 2022 in Legal Alerts
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 book profits exceeding $1 billion effective for taxable years beginning after December 31, 2022 (the AMT). Originally a provision of the now-defunct Build Back Better Act, the AMT was...
Legal Alert: Inflation Reduction Act of 2022 signed into law – A summary of the energy tax provisions
Posted on Aug 16, 2022 in Energy Tax, Legal Alerts
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 substantial extensions, expansions and modifications of the tax credits for renewable and alternative energy development. In one of the best-kept secrets in Washington, Senators Manchin...
Legal Alert: Inflation Reduction Act targets carried interests
Posted on Jul 30, 2022 in Legal Alerts
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 expand the scope of IRC section 1061, which generally imposes limits on tax benefits available to carried interests and other compensatory partnership interest arrangements. Read the full...
Legal Alert: Back from the dead – Corporate minimum tax resurfaces at eleventh hour in Inflation Reduction Act of 2022
Posted on Jul 29, 2022 in Legal Alerts
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). Although months ago the $2 trillion BBBA was declared dead, Senators Joe Manchin and Chuck Schumer introduced the skinnied-down $739 billion proposal Wednesday, with its submission to the...
Legal Alert: A welcome clean energy surprise – Inflation Reduction Act includes energy tax extensions and expansions
Posted on Jul 29, 2022 in Legal Alerts
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 tax provisions aimed at enhancing US energy security. Tax pay-fors in the bill include a corporate minimum tax and an increase in the tax rate on carried interest. A...
Legal Alert: Downsizing from a House to a Manchin: Federal and International tax negotiations continue
Posted on Jul 8, 2021 in Legal Alerts
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 regarding a bipartisan infrastructure deal and a minimum global tax, the details of most corporate tax proposals have yet to be decided. Of course, the most pressing question remains –...
Legal Alert: FY 2022 Green Book goes big for green energy
Posted on Jun 1, 2021 in Energy Tax, Legal Alerts
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 provides further detail on the White House’s American Jobs Plan, one of the major proposals in the development of an infrastructure bill. The Green Book’s release comes as Congress works...
State of play: A May methods update
Posted on May 19, 2021 in Legal Alerts, Tax Accounting
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 provided updates to taxpayers and practitioners on the status of guidance projects, and offered clarification regarding certain recent legislative proposals. IT&A leadership acknowledged...
The Made in America Tax Plan Webcast Series
Posted on May 11, 2021 in Presentations
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 Overview of the Legislation Highlighting Key Federal Tax ProvisionsAs part of Biden’s American Jobs Plan, the President has rolled out his opening offer to change the American corporate tax...
Who in the world is Joe Manchin: International tax proposals vary under Biden, Senate proposals
Posted on Apr 23, 2021 in International Tax, Legal Alerts
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 President Biden1 and the Senate Finance Committee2 to overhaul international tax have arrived. While similarities are present between the two proposals, including raising the corporate...
CARES Act Amends TCJA Provisions
Posted on Mar 30, 2020 in Uncategorized
On March 27, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act. While the Act is primarily focused on the coronavirus epidemic, the Act made a few significant changes to provisions enacted by the Tax Cuts and Jobs Act (TCJA). The Act: • Allows net operating losses (NOLs) arising in 2018, 2019, or 2020 to be carried back five years and exempts NOLs from the...
Bill to Correct Qualified Improvement Property Glitch Fails to Gain Traction in the House
Posted on Nov 22, 2019 in Tax Accounting
On Nov. 20, the House of Representatives failed to approve a motion that would have attached the Restoring Investment in Improvement Act (H.R. 1869) to the Workplace Violence Prevention for Health Care and Social Service Workers Act (H.R. 1309). H.R. 1869 would correct a drafting error in the Tax Cuts and Jobs Act changes to section 168 that prevents qualified improvement property from...
Treasury Releases Final and Proposed GILTI Regulations and Temporary Section 245A Regulations
On June 14, Treasury and the IRS (the Service) released final and proposed regulations on the new global intangible low-taxed income provisions, or GILTI, that were introduced under the Tax Cuts and Jobs Act. Along with finalizing regulations related to determining a US shareholder’s GILTI inclusion and their pro rata share of a CFC’s subpart F income, the regulations also address the...Passthrough Regulations and Guidance Released
Posted on Jan 24, 2019 in News, Tax Accounting
Final section 199A regulations and additional proposed rules concerning passthrough deductions were released on January 18. The final regulations concern the 20 percent business income deduction available to passthrough owners meeting certain income thresholds that was introduced under the Tax Cuts and Jobs Act (TCJA). Included in the final regulations are a technical definition of...