Tax Law News and Insights

I.  Introduction On December 19, 2019, the IRS and Treasury issued final regulations on the Opportunity Zone program. The Opportunity Zone program is intended to encourage investments in economically distressed qualified opportunity zones (QOZs) by allowing taxpayers to defer and, in some cases, reduce or eliminate tax on capital gains...

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On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs Act (TCJA) statutory changes and expense apportionment. (For a discussion of the 2018 proposed...

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Summary The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT). The final regulations, based partly on the IRS's response to comments received, clarify previously proposed regulations, such as providing that certain amounts transferred in connection with...

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