On October 5, the U.S. Treasury released long-awaited proposed regulations regarding inbound cross-border reorganizations, implementing (with modifications) policies that had been announced in 2014 and 2016 notices.
Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.
An important Upper Tier decision illuminates the meaning of “significant influence” in UK tax legislation.
After almost 20 years, the IRS has again ruled that the conversion under state law of a limited liability company (LLC) disregarded for tax purposes to a corporation did not result in a “significant modification” of the various classes of debt previously issued by the LLC (PLR 202337007, released September 15, 2023).
Treasury appears to be expanding participation in the new transferability provisions for clean energy tax credits — and may even allow individuals to purchase credits.
On September 29, 2023, Treasury released the 2023-2024 Priority Guidance Plan, which included “Guidance under section 1402(a)(13),” signaling the government’s intention to finally clarify the confusion surrounding the limited partner exception.