Tax Law News and Insights

Highlights Under Proposed Regulations issued in October 2024 by the U.S. Department of the Treasury and IRS, an entity wholly owned by one or more Tribal governments and organized or incorporated under the laws of the Tribe or Tribes that own it (Tribally chartered entities) is not recognized as a...

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Treasury and the IRS have finalized a new "disregarded payment loss" (DPL) regime that can require domestic corporations to include in income amounts with respect to payments that are disregarded for US tax purposes but that are deductible under foreign tax law. Proposed regulations addressing DPLs, as well as aspects...

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Last month, the Department of the Treasury and the Internal Revenue Service ("IRS") issued proposed regulations updating the rules for tax professionals who practice before the IRS. These rules, which are contained in Treasury Department Circular 230 ("Circular 230") and apply to attorneys, certified public accountants, and enrolled agents who...

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