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I. Introduction The Internal Revenue Code taxes U.S. persons on all of their worldwide income, from whatever source derived. (1) This creates a double taxation problem with respect to a [...]

Internal Revenue Service Notice 2023-80 (hereinafter "the notice") provides the US government's view on the foreign tax credit treatment of Pillar Two top-up taxes and makes a clear distinction between [...]

I. Introduction On October 8, 2021, 136 countries signed the Organization for Economic Co-operation and Development ("OECD") Base Erosion and Profit Shifting ("BEPS") statement ("the Statement"). (1) The Statement was [...]

A recent Tax Court case concerning a taxpayer's eligibility for Sec. 41 research credits, Betz, (1) provides insights regarding the IRS's and the court's recent interpretation of the Sec. 41(d)(4)(B) [...]

Since Dec. 31, 2021, when, within the depths of the COVID-19 pandemic, a five-year investment-rated municipal ("muni") bond paid only 0.6%, returns have significantly risen (e.g., the BVAL Muni Benchmark [...]

Editor's Note: Elisabeth Griffith is the author of two acclaimed books on women's history, Formidable: American Women and the Fight for Equality: 1920-2020 and In Her Own Right: the Life […]

Over the course of the past three years, the Employee Retention Credit (ERC) has become a widely known term among businesses in the United States. Whether it was by way [...]

The Inflation Reduction Act of 2022 (IRA) greatly expanded energy-related federal income tax credits and created Internal Revenue Code Section 6418, which allows eligible taxpayers to transfer, or sell, certain [...]

Late on January 31, 2024, the House passed the Tax Relief for American Families and Workers Act of 2024 by a 357 - 70 vote. The bill provides for increases [...]

As 2023 was ending, the U.S. Department of Treasury and the Internal Revenue Service (IRS) released helpful guidance regarding foreign tax credits (FTCs). Notice 2023-80 extends relief provided in a [...]

The Internal Revenue Service (IRS) is finally catching up with the significant guidance requirements for the clean energy credits of the Inflation Reduction Act. Temporary and proposed regulations and notices [...]

Taxpayers claiming research and development (R&D) tax credits for work performed under contract must contend with the exclusion for "funded research." Whether R&D is funded involves a two-pronged analysis to [...]

As of this writing, March 1, 2024, the House and Senate have just agreed on a one-week extension of the budget deadline and hope to have appropriations bills enacted by [...]

Byline: Special to the RBJ The results of this month's election could have an impact on the scheduled end-of-2025 sunsetting of the Tax Cuts and Jobs Act (TCJA) of 2017, [...]

It is easy enough to understand what is motivating Kamala Harris's economic strategy. Poll after poll demonstrates that many Americans consider the cost of living to be their https://www.economist.com/leaders/2024/08/08/will-americas-economy-swing-the-election heading [...]

A proposed rule from the Consumer Financial Protection Bureau (CFPB) would curtail the inclusion of medical debt in credit evaluations, potentially shaking up healthcare billing and collections processes. The CFPB [...]

Table of Contents I. Overview of Qualification for LIHTCs with Tax-Exempt Bond Financing 330 II. 50% Test Complexities 333 A. When Do Amounts Have to Be Expended to Be Included [...]

Tables of Contents Introduction 381 Brief Overview of LIHTC Transactions 382 Decision-Making Authority 383 Allocating the Deal's Economic Benefits and Risks 386 Right of First Refusal 390 Conclusion 391 Introduction [...]

Just because Congress failed to act on passing any significant legislation affecting taxes, although they did take some money away from the Internal Revenue Service, it does not mean there [...]

I. Introduction 189 II. Background 191 A. Truth in Lending, Full Disclosure, and APR 191 B. Dodd-Frank and the Birth of the CFPB 193 C. The Rise of Fintech 194 [...]

This survey concentrates on the most significant letter of credit ("LC") (1) issues addressed in cases decided primarily in the United States (2) in the year 2022 and also comments [...]

The U.S. federal income tax system generally subjects U.S. taxpayers to taxation of earnings from all sources, foreign and domestic. To prevent double taxation, a credit against U.S. federal income [...]

The Inflation Reduction Act of 2022, P.L. 117-169, signed into law on Aug. 16, 2022, is considered the largest investment in clean energy in history, providing an estimated $663 billion [...]

U.S. companies have gone from leading global semiconductor chip production at the inception of the industry to comprising only approximately 12% of global production capacity today. According to the Semiconductor [...]

As part of the Inflation Reduction Act, Congress enacted a new corporate alternative minimum tax (CAMT) that may prove both expensive and cumbersome for large multinationals. Added to the insult [...]

Treasury determined that taxpayers are required to allocate and apportion U.S. shareholder deductions (including those for interest expense) to global intangible low-taxed income ("GILTI") in 2019 when it issued final [...]

The IRS moved on Sept. 14 to stem what it called a "flood" of improper claims of the employee retention credit (ERC), by placing an immediate moratorium on the processing [...]

Before exploring what Joe Biden or Donald Trump did or didn't do for America's working families, we need to start with a reality check: American families are struggling. Although there [...]

The Inflation Reduction Act of 2022, P. L. 117-169, addec new Sec. 6418 to the Internal Revenue Code, allowing eligible taxpayers to transfer (or sell) all or a specified portion [...]

March 1, 2024 RELATED March 13, 2024 Decision holding Corporate Transparency Act unconstitutional appealed January 1, 2024 Apportioning tax benefits among members of a controlled group January 1, 2024 Energy [...]

Byline: Nick Garber New York's newly expanded tax credit for film productions is a 'net negative' that fails to give taxpayers a return on their investment, even as state leaders [...]

The House of Representatives passed a $78bn tax bill with rare bipartisan support, 357 votes to 70. The bill would give more low-income families access to expanded child tax credits [...]

February 1, 2024 Recent changes to the treatment of research and experimental (R&E) expenditures for federal income tax purposes beginning with the 2022 tax year are having a significant impact [...]

Editors note: This article was written in mid-December 2022. It is expected that by the time of publication, the US Department of Treasury and the Internal Revenue Service may release [...]

Unless otherwise noted, contributors are members of or associated with Deloitte Tax LLP. For additional information about these items, contact Mr. Brosseau at 202-661-4532 or abrosseau@deloitte.com. In This Department CORPORATIONS [...]

As in life, there are many surprises in tax law. In the world of taxes, it is a cliche to say that what seems simple usually turns out to be [...]

As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the "final regulations") (1) finalizing the proposed [...]

For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have [...]

This article is the second part of Chapter 9, Controlled Foreign Corporations, from the authors' most recent edition of UNITED STATES INTERNATIONAL TAXATION: OUTBOUND AND INBOUND ACTIVITIES. [paragraph] 9.26 Global [...]

Byline: Eddie Small Politicians, developers and the construction industry are ready for another round of efforts to replace New York's controversial, now expired 421-a affordable housing tax break. The proposal [...]

January 1, 2024 Cost recovery of specified research or experimental (SRE) expenditures is governed by Sec. 174. Subsection (d), added by the law known as the Tax Cuts and Jobs [...]

January 1, 2024 The IRS's Large Business and International (LB&I) Division announced updates to the Compliance Assurance Process (CAP) program for tax year 2024 and beyond (News Release IR-2023-164). Program [...]

Imagine that you are a fairly sophisticated investor and your broker has added a publicly traded partnership (PTP) to your portfolio. You trust your broker to invest wisely on your [...]

CPAs assessing the start of this year's round of client tax return preparation can take some satisfaction in knowing that they're not likely to face a repetition of last year, [...]

Do you want the good news or the bad news first? The bad news is that research credits are not getting easier to claim in 2024. Internal Revenue Service audits [...]

On November 17, 2023, Treasury and the Internal Revenue Service (IRS) issued proposed regulations addressing the Code Sec. 48 investment tax credit. The proposed regulations reflect not only the changes [...]

Tabled in the U.S. House of Representatives by Congressman Kevin Brady on November 2, 2017, and officially signed into law by President Donald Trump on December 22, 2017, the Tax [...]

I. Introduction As many readers already know, on December 28, 2021, the Treasury Department and the Internal Revenue Service (the "IRS") issued final regulations relating to the allocation and apportionment [...]

Introduction 35 I. Background 37 A. Overview of the LIHTC Program 39 B. Investors and the Role of Private Capital 40 C. The Role of Nonprofits 42 II. Year 15 [...]

On April 30, 2021, the Internal Revenue Service released early drafts of the new Schedules K-2 and K-3 for Forms 1065, 1120-S, and 8865 for tax year 2021. Why did [...]