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 of 2022 – The energy tax provisions you need to know about
Posted on Aug 4, 2022 in Legal Alerts
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 renewable and alternative energy tax credits, shift to technology neutral credits in 2025, provide for US energy component manufacturing credits and modify the rules for electric vehicle tax...
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: An incomplete picture: Democratic senators release “framework” for international tax overhaul
Posted on Aug 31, 2021 in International Tax, Legal Alerts
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 legislative language is generally in line with the International Tax Overhaul proposals first released by the Senators on April 5, 2021. The draft legislation includes some provisions...
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...
Treasury and IRS Release Final Regulations under Section 163(j) with respect to Partnerships and CFCs
Posted on Jan 5, 2021 in International Tax
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 limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income (ATI). The regulations finalize...
OMB Completes Its Review of Proposed Regulations under Section 163(j)
Posted on Jan 5, 2021 in International Tax
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 business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The proposed regulations provide rules applicable to partnerships and controlled foreign...