On January 7, 2021, the Internal Revenue Service (the "IRS") and the Department of the Treasury released final regulations (the "Final Regulations") implementing the provisions of Section 1061 of the U.S. Internal Revenue Code of 1986, as amended (the "Code"). Section 1061, which was enacted as part of the most recent U.S.
In this alert, we provide a brief overview of the main rules under Section 1061 and highlight several of the most relevant revisions and clarifications included in the Final Regulations.
Many things are taking place:
JPT IRS Issues Final Rules on CCS Tax-Credits Regulations
Russia flares more associated gas from oil production than any other country on the planet. But Russian major Gazprom Neft may have found an ecofriendly alternative: turning flare gas in West Siberia into electricity to fuel the mining of cryptocurrency.
The storage of carbon dioxide under the seabed may add millions of tons per year to global carbon-capture totals. The finance and investment sectors are recognizing the value these projects may bring to portfolios aligned with achieving climate-change goals.
Final rules on exempt organization excess remuneration - Journal of Accountancy
Tax-exempt organizations received guidance from the IRS on Tuesday regarding the excise tax on compensation in excess of $1 million and certain parachute payments. The IRS issued the final regulations ( T.D. 9938 ) under Sec. 4960, which was added to the Code by Section 13602 of the law known as the Tax Cuts and Jobs Act, P.L. 115-97. The rules finalize proposed regulations (REG-122345-18) issued in June 2020. Sec. 4960 is effective for tax years beginning after Dec. 31, 2017.
Final Regulations on Exempt Organization Excess Compensation Excise Tax - Lexology
The final regulations reserve on the question of whether a federal instrumentality for which an enabling act provides for exemption from all current and future federal taxes is subject to tax under section 4960. Until further guidance is issued, such an instrumentality may treat itself as not subject to tax under section 4960 as an ATEO or related organization.
The final regulations also reserve on the coordination of sections 4960 and 162(m) in circumstances where there is a difference in timing between vesting and payment of remuneration.
Other things to check out:
Anticipated Energy and Environmental Admin Policy Changes
Although bipartisanship will still be necessary to advance several priorities, Congressional Democrats can use a number of procedures to advance their agenda with simple majority votes to avoid significant compromises with Republicans. Below are three areas where Biden and Democrats can move their energy and environmental agenda in the weeks and months to come.
Confirmations —The confirmation process for senior administration officials will be easier and only require majority votes (with Vice President-elect Kamala Harris as the tie-breaker when needed).
IRS Final-Carried Interest Regulations More Favorable to Fund Managers - Lexology
The Treasury Department and the IRS have scaled back the proposed related party transfer rules under Section 1061, now requiring recharacterization rather than acceleration of gain
The final regulations provide limited relief for qualifying capital interests to be excluded from Section 1061 treatment, offering less rigidity
The rules now will “look through” to the partnership’s assets where a partner satisfies the three-year holding period only where there is a principal purpose of avoiding the application of Section 1061
IRS Working on Guidance for Expense Allocation Election
The IRS is writing guidance to implement a pre-2017 tax law election that lets companies use a different method of allocating interest expenses when calculating their limit on foreign tax credits, an agency official said.
The election, under tax code Section 864(f) , allows companies to allocate their interest expenses on a worldwide basis, which would take income and expenses of controlled foreign corporations into account and make more foreign tax credits available in certain situations.
COVID-19 exposed what Iowa doesn't need, and what it does, to propser
With the state Legislature back in session, lawmakers have an opportunity to tackle some of the biggest barriers to opportunity and prosperity faced by Iowans. They should seize the moment.
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The current pandemic may have placed a spotlight on health care, but our health care system was broken long before COVID-19 struck. The rapid spread of the virus highlighted some valuable lessons that lawmakers can learn from and act on.
Through various regulatory barriers, including scope-of-practice restrictions and certificate-of-need laws, Iowa places limits on the supply of health care.
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