Tyler J. Moser
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On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of Section 367(d)[1] when intangible property is repatriated back to the United States. The proposed Regulations represent a taxpayer-favorable position for taxpayers that have considered repatriating intangible property … Continue Reading
On March 9, 2023, the Biden Administration released the Fiscal Year 2024 Budget, and the “General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals,” which is commonly referred to as the “Green Book.” The Green Book summarizes the Administration’s tax proposals contained in the Budget. The Green Book is not proposed legislation, and each of … Continue Reading
On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law. The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a two-year extension of the excess business loss limitation rules. The IRA also contains a number of energy tax provisions. I. … Continue Reading
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The IRA contains a significant number of climate and energy tax proposals, many of which were previously proposed in substantially similar form by the House of Representatives in November 2021 (in the “Build Back Better Act”). Extension and expansion of production … Continue Reading
Proposed Regulations Issued for Repatriations of Intangible Property under Section 367(d)
By Richard M. Corn, Martin T. Hamilton, Amanda H. Nussbaum and Tyler J. Moser on Posted in Tax Policy, U.S. Legislation
Proskauer Tax Talks: Green Book 2024
By David S. Miller, Amanda H. Nussbaum, Martin T. Hamilton, Jean Bertrand, Rita N. Halabi, Martine Seiden Agatston, Tyler J. Moser and Alliyah J. Brown on Posted in Corporate tax, In the news, Tax, Tax Policy, Tax Reform, U.S. Legislation
