Joshua D Odintz

Dec 6, 2024 | jdsupra.com | Christopher Armstrong |Nicole Elliott |Joshua D Odintz

Republican control of the White House, U.S. Senate and U.S. House of Representatives presents an opportunity to enact law without the need for bipartisan support. Specifically, congressional Republicans will use the budget reconciliation process to pass significant legislation, and they could do so early in 2025. The budget reconciliation process, while a powerful tool when one party controls, does have some notable limitations.

Oct 30, 2024 | jdsupra.com | Nicole Elliott |Mary Nicholson |Joshua D Odintz

The Chips and Science Act of 2022 (CHIPS Act) added Section 48D to the Internal Revenue Code to incentivize the manufacture of semiconductors and semiconductor manufacturing equipment. The Section 48D credit is generally 25 percent of the basis of any qualified property that is part of an eligible taxpayer's advanced manufacturing facility. The U.S. Department of the Treasury and IRS recently released final regulations under Section 48D, which provide helpful clarifications.

Apr 26, 2024 | jdsupra.com | Mary Nicholson |Joshua D Odintz

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise tax. Comments on the Proposed Regulations are due by June 11, 2024.

Aug 21, 2023 | news.bloomberglaw.com | Joshua D Odintz

On Aug. 4, the Department of the Treasury and IRS published a Notice of Proposed Rulemaking to treat certain monetized installment sale transactions as listed transactions. This means the IRS has determined them to be tax avoidance transactions. Usually, the IRS has announced listed transactions through revenue rulings or notices that aren’t subject to public comment and don’t require advance warning—it has issued 39 revenue rulings and notices to date.