Eversheds Sutherland Tax Reform Law Blog
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Legal Alert: Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: Allows controlled foreign corporations (CFCs) to obtain automatic consent to change depreciation methods to use the alternative depreciation system under section 168(g) (ADS) (or...

State of play: A May methods update

At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and practitioners on the status of guidance projects, and offered clarification regarding certain recent legislative proposals. IT&A leadership acknowledged...

Senate Finance Committee Provides Congressional Intent Behind TCJA Concepts

The Senate Finance Committee Republicans sent a letter to Treasury asking that its guidance on provisions of the Tax Cuts and Job Act reflect congressional intent. The letter specifically identified three errors to be corrected by technical correction legislation: the effective date of the net operating loss carryforwards and carrybacks should begin after December 31, 2017; qualified...