Interest claim limitation periods, including for ‘net rate’ netting claims
Various periods of limitation apply to claims filed with the IRS in the context of underpayment interest under Sec. 6601...
Guidance on clean vehicle tax credit
Aug 30, 2022
Treasury and the IRS released initial guidance on Tuesday regarding a new requirement to qualify for the Sec. 30D clean vehicle tax...
Nonliquidating distributions: Ways to determine basis
Aug 26, 2022
A partnership that distributes a partial interest in partnership property must apportion the tax basis in the property between the...
Foreign tax credit requires consistency
Aug 23, 2022
Under the consistency rule in Temp. Regs. Sec. 1.861-9T(f)(3)(iv), for purposes of calculating its foreign tax credit, a taxpayer could...
Key tax provisions in the Senate reconciliation bill
Aug 19, 2022
By a vote of 51 to 50, the U.S. Senate on Sunday passed a budget reconciliation bill, H.R. 5376, now known...
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