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May 22, 2024

Earlier this month, the IRS released Revenue Procedure 2024-24, which sets forth new requirements for requests for private letter rulings on corporate spin-off and split-off transactions. 

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On April 30, 2024, the DOJ announced the unsealing of an indictment charging “Bitcoin Jesus” with mail fraud, tax evasion and filing false tax returns.

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The UK’s Court of Appeal takes a pragmatic view of the availability of tax relief for interest costs in its much-awaited judgement in BlackRock Holdco 5.

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Treasury has released the final rules on sales of energy tax credits under the Inflation Reduction Act of 2022.  Although some may be disappointed that suggestions for improving the market were ultimately not adopted, a robust market is already operating within the confines of the existing rules.

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Advocate General opines on the UK’s upcoming CFC/state aid case with the EU Court of Justice.

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In November 2023, the IRS issued proposed regulations relating to donor-advised funds (discussed here). The regulations define certain terms such as DAFs, Donors, and Donor-Advisors, and describe taxable distributions that are subject to certain excise taxes. Since the release of the regulations, there have been several notable developments.

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The Tax Court recently ruled that a new partnership that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership, rejecting the government’s argument that a new taxable year begins on the day after the technical termination.

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On April 15, the IRS released Notice 2024-33, offering limited relief from tax penalties for underpaying estimated income taxes arising from a corporation’s alternative minimum tax.

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