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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act.

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate alternative minimum tax (the “CAMT”), which was enacted two years ago as part of the Inflation Reduction Act (“IRA”).

On September 12, 2024, the Department of the Treasury and the Internal Revenue Service issued long-awaited proposed regulations (the “Proposed Regulations”) on the application of the corporate alternative minimum tax, which imposes a 15% corporate alternative minimum tax on the adjusted financial statement income (“AFSI”) of certain large corporations for tax years beginning after December 31, 2022.

Partner Chris Mangin, with assistance from Partner Paige Anderson, led the ABA Section of Taxation’s comment letter (the “Comments”) on Treasury and the IRS’s recently proposed regulations under Sections 897 and 892 (the “Proposed Regulations”) regarding issues affecting foreign investment in U.S. real estate.

Just eight weeks after former Chancellor Kwasi Kwarteng unexpectedly announced the largest package of tax cuts implemented in the UK since the 1970s, the UK Government has now effectively gone into full reverse following new Chancellor Jeremy Hunt’s Autumn Statement, delivered on 17 November 2022, in which he announced a £55 billion combined package of tax rises and spending cuts intended to shore up the UK’s public finances.

Following a highly negative response from the financial markets and the IMF, amongst others, to the UK Government’s “Growth Plan 2022” (released on 23 September 2022 by the then-new Chancellor Kwasi Kwarteng and summarised by us here) (the “Mini-Budget”), the replacement Chancellor Jeremy Hunt made an Emergency Statement on 17 October in which he announced, by way of a major Government “U Turn”, that almost all of the tax measures set out in the former Chancellor’s Mini-Budget would not now be implemented.

Against a backdrop of rising inflation and increasing concern about a “cost of living crisis” in the UK, the newly appointed Chancellor, Kwasi Kwarteng, laid out the Government’s plans for growing the UK economy in his “Growth Plan 2022”, released 23 September 2022.

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum tax on certain corporations (the “CAMT”).

HMRC has recently updated its guidance on the UK’s new qualifying asset holding company (QAHC) tax regime, which was introduced from 1 April 2022, to include examples of the application of the QAHC regime “activity condition” to credit funds (i.e. the requirement for a QAHC to carry out mainly investment business, with any other activity, such as trading, being ancillary to it and not carried on to any substantial extent).

There are growing calls for a carbon tax on shipping emissions. Jim Loftis, Ciara Ros, and Tatiana Freeman of Vinson & Elkins look at the recent proposal from Japan for a global carbon tax, assess it in the context of the existing approaches in other jurisdictions and industries and consider how those involved in the maritime industry need to prepare.