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Inflation Reduction Act
How Governments Can Help Put the "Opportunity" in Opportunity Zones
First introduced by the tax reform legislation signed into law in late 2017, Opportunity Zones present a new opportunity for taxpayers to defer and/or eliminate tax liability and, at the same time, spur much needed economic development in underserved communities...
IRS and Treasury Department Release Proposed Regulations on Opportunity Zones
On October 19, 2018, the IRS and Treasury Department released highly-anticipated proposed regulations (the Proposed Regulations) under Section 1400Z-2 of the Internal Revenue Code of 1986, as amended (the OZ Statute). The OZ Statute, which was enacted pursuant to the...
Hospital Loses its Section 501(c)(3) Status Due to Noncompliance with Section 501(r)
The IRS recently issued a Private Letter Ruling (the “PLR”) revoking a hospital organization’s section 501(c)(3) status for failing to comply with the section 501(r) requirements. 1 In what may be a sign of things to come, the PLR serves...
Congress Heads Home After 2.0 Victory Lap; Election to Determine Fate of Lame Duck Loose Ends
In their last legislative action before the midterm elections, House Republicans earlier this month passed a three-bill package dubbed “ Tax Reform 2.0 ” in a bid to cement their signature legislative accomplishment in voters’ minds. The bills passed largely...
IRS Issues Interim Guidance Applicable to Tax-Exempt Investors in Private Equity Funds
On August 28, 2018, the IRS released Notice 2018-67 (the Notice), which provides interim guidance concerning the aggregation of trade or business activities for purposes of calculating the unrelated business taxable income (UBTI) of a tax-exempt organization. The Notice was...
House Republicans Seek to Lock In, Expand Tax Cuts With "2.0"
House Ways and Means Committee Chairman Kevin Brady (R-TX) last week released and ultimately approved a long-awaited package of legislation dubbed “Tax Reform 2.0.” The legislative text fleshes out the “listening session framework” put out by the Chairman shortly before...
Proposed Regulations on the 20% Deduction for Qualified Business Income Provide Helpful Guidance for the Energy Industry
On August 8, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) providing guidance on the deduction equal to 20% of an individual’s qualified business income (QBI). As discussed here in greater detail, pursuant to Section 199A...
Proposed Regulations on Immediate Expensing Provide Greater Clarity for the Energy Industry
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). As discussed here in greater detail, the TCJA...
Focus on Finance: Tax Reform and the Banking Industry Revisited
The Tax Cuts and Jobs Act (TCJA) has far-reaching implications for the banking and finance industry. In our very first Bracewell Tax Report (click here for more), we noted certain issues that companies might consider when evaluating their financing options...
IRS Guidance on the Application of Tax Reform Amendments to Code Section 162(m)
On August 21 st , the IRS issued Notice 2018-68 which provides initial guidance regarding amendments to Section 162(m) of the Internal Revenue Code (“Section 162(m)”) as provided by the 2017 Tax Cuts and Jobs Act passed in late 2017...
FY 2019 Sequestration Reduction Rate for Direct Pay Tax Credit Bonds Set at 6.2 Percent
According to the IRS website , the sequester reduction rate applied to payments made to issuers of direct pay tax credit bonds in fiscal year 2019 will be 6.2 percent . This percentage will apply to all subsidy payments scheduled...
The New Partnership Audit Rules, Part 7: What Lies Ahead
This is the seventh installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
House Republicans Seek a Victory Lap With Tax Cuts 2.0
With Congress wrapping up its Summer work and August recess rapidly approaching, the tax agenda for the remainder of the year has started to come into focus. With hopes for a ride on the must-pass aviation bill all but dashed...
Extenders Mean Groundhog Day for Congressional Taxwriters
The estimable Chairman of the Ways and Means Committee has had it with the annual “extenders” charade. House tax-writers will sort through the list of temporary tax provisions and determine once and for all what deserves to be part of...
IRS Says "Yes" to Leveraged Partnerships and "No" to Bottom Dollar Guarantees... At Least for Now
On June 18, 2018, the IRS issued proposed Treasury regulations (the 2018 Regulations) that, if finalized, would withdraw certain proposed and temporary Treasury regulations issued in 2016 related to the allocation of partnership liabilities (the 2016 Regulations). In their place...