How the new corporate AMT affects foreign-owned U.S. companies
Explaining how the new 15% corporate alternative minimum tax (AMT) in the Inflation Reduction Act of 2022 could significantly affect foreign-owned U.S.
Treasury releases much anticipated proposed FTC regulations
Last Friday, Treasury released proposed foreign tax credit regulations aiming to clarify the cost recovery requirement and royalty withholding ...
Clean energy incentives for manufacturers
The Inflation Reduction Act of 2022 provides new and expanded clean energy incentives for businesses in the manufacturing sector
New credit amounts for the Production Tax Credit for 2022
IRS announces new tax credit amounts under section 45 of the Internal Revenue Code, for the calendar year 2022.
OECD issues final Crypto-Asset Reporting Framework – now what?
The OECD’s updated crypto-asset reporting framework and CRS amendments will streamline reporting and exchange of information on crypto-assets.
Treasury Priority Guidance Plan 2022-2023 – Exempt Organizations
The Treasury Department and the IRS released the 2022-2023 Priority Guidance Plan, which contains a number of items affecting exempt organizations.
Year-end tax planning considerations
Tax planning considerations for businesses and individuals approaching the end of 2022.
Business tax considerations amid economic headwinds
Tax considerations to help your business fight economic factors that could lead to a recession.
IRS makes statements on CARES Act Employee Retention Tax Credit risks
On Oct. 19, 2022 the IRS issued a news release warning employers to be wary of third parties who have ramped up campaigns to try and get ...
IRS releases required minimum distribution (RMD) guidance
Notice 2022-53 announced the IRS’s intent to publish final regulations addressing required minimum distributions (RMDs) from certain plans.
New IRS draft forms reflect broader digital asset enforcement
The IRS changed “virtual currency” to “digital asset” in new draft forms, signaling enforcement efforts toward digital assets, including NFTs.
IRS provides simplified measures for correcting common S corporation missteps
IRS Rev. Proc. 2022-19 provides S corporations with simplified procedures to resolve common issues without a private letter ruling.
Distressed acquisitions & credit bidding debt: an M&A tax perspective
Tax considerations for buyers and sellers of distressed companies under section 363 of the Bankruptcy Code.
Treasury releases technical corrections to final FTC regulations
IRS releases a set of technical corrections (2022-15867 and 2022-15868) to calm taxpayer concerns regarding the final FTC regulations.
Eleventh Circuit reverses Tax Court’s penalty approval analysis.
The Eleventh Circuit overrules the Tax Court and holds supervisory approval any time before assessment satisfies section 6751(b).
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