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Inflation Reduction Act
The CARES Act Provides Significant Relief With Respect to Distributions From Qualified Retirement Plans
Late last night, the U.S. Senate passed by a vote of 96-0 the Coronavirus Aid, Relief and Economic Security Act (the CARES Act). In addition to, among other things, financial assistance to individuals and certain businesses, the CARES Act provides...
COVID-19 Tax Update: Tax Return Filing and Tax Payment Relief
Last week, in a pair of notices released under President Trump’s March 13, 2020 Emergency Declaration relating to the coronavirus pandemic, the IRS and the Treasury Department offered relief for tax return filing and tax payment deadlines to certain taxpayers...
Tax Relief under High Deductible Health Plans for COVID-19 Testing and Treatment
Due to the rapid spread of COVID-19, the Internal Revenue Service has issued Notice 2020-15 (the “Notice”) to provide relief for high deductible health plans (“HDHPs”) with respect to providing health benefits associated with testing for and treatment of COVID-19...
Final Regulations and New Proposed Regulations on Immediate Expensing: Implications for Energy and Infrastructure
On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate expensing (Bonus Depreciation) under the Tax Cuts and Jobs...
Utilizing REITs for Midstream Assets
The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations, generally with only a single level of federal...
GREEN Act Update
House Democrats today released their long-awaited package of clean energy tax incentives, the Growing Renewable Energy and Efficiency Now (GREEN) Act . In a release accompanying the legislative text and section-by-section summary , Ways and Means Select Revenue Subcommittee Chairman...
Proposed Rules Addressing LIBOR Phase-out Help Ease Reissuance Concerns
Since the 2017 announcement that the London interbank offered rate (“LIBOR”) may be phased out after the end of 2021, the municipal finance industry has been concerned that changes to debt obligations and related financial products necessary to address the...
Transaction Tax Deductions Following Tax Reform
In connection with the purchase and sale of the stock of a target corporation (a Corporate Target), the target often incurs various transaction costs (Transaction Costs) that may yield significant tax deductions (Transaction Tax Deductions). If such Transaction Tax Deductions...
SECURE Act Provisions
Major changes in federal law are in the works that could significantly impact employers’ qualified retirement plans, which could require amending such plans to reflect mandatory and elective changes. The U.S. House of Representatives recently passed the Setting Every Community...
Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations
After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “ Second Tranche ”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act of...
New Requirements for Deducting Payments to Governmental Entities
Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity, including certain...
IRS Issues Final Regulations on Partnership Audit Rules
On December 21, 2018, the Treasury Department and IRS released final regulations (the Regulations) implementing the federal audit regime for partnerships, and entities classified as partnerships for federal income tax purposes, enacted under the Bipartisan Budget Act of 2015 (the...
IRS Provides Long-Awaited Guidance for Partially-Regulated Energy Companies under Code Section 163(j)
On November 26, 2018, the Treasury Department and IRS released proposed regulations (the Proposed Regulations) interpreting the limitation on the deductibility of business interest expense (Interest Expense) under Code Section 163(j), enacted under the Tax Cuts and Jobs Act (the...
IRS Reporting Requirements – 2018 Employee Stock Transactions
Now that 2019 has begun, corporations should be aware of IRS reporting requirements regarding certain 2018 stock transactions with their employees. Section 6039 of the Internal Revenue Code of 1986, as amended (the “Code”), requires a corporation to report (i)...
It's Official! Final Public Approval Regulations Now Reflect the 21st Century
Treasury has released final regulations (the “ Final Regulations ”) relating to the public approval requirements for private activity bonds (aka the “TEFRA approval” process). The Final Regulations effectively track the proposed regulations issued in 2017 (the “Proposed Regulations”), but...