Eversheds Sutherland Tax Reform Law Blog
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Legal Alert: Inflation Reduction Act targets carried interests

On July 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act).  The proposed legislation includes changes that would expand the scope of IRC section 1061, which generally imposes limits on tax benefits available to carried interests and other compensatory partnership interest arrangements. Read the full...

Legal Alert: Back from the dead – Corporate minimum tax resurfaces at eleventh hour in Inflation Reduction Act of 2022

On July 27, 2022, the Senate announced agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 (the IRA), the artist formerly known as the Build Back Better Act (the BBBA). Although months ago the $2 trillion BBBA was declared dead, Senators Joe Manchin and Chuck Schumer introduced the skinnied-down $739 billion proposal Wednesday, with its submission to the...

Legal Alert: A welcome clean energy surprise – Inflation Reduction Act includes energy tax extensions and expansions

In a surprising turn of events, late on July 27, 2022, Senators Manchin (D-WV) and Schumer (D-NY) released the Inflation Reduction Act of 2022. The Act, which runs 725 pages, includes numerous energy tax provisions aimed at enhancing US energy security. Tax pay-fors in the bill include a corporate minimum tax and an increase in the tax rate on carried interest. A...