Wednesday, July 22, 2020
The Columbia Journal of Tax Law has published a new issue of its Tax Matters feature:
Kristin E. Hickman (Minnesota), 245A and T.D. 9865: Two Steps Forward, One Step Back for Temporary Treasury Regulations?:
In June 2019, the Treasury Department (Treasury) adopted temporary regulations implementing the new § 245A, enacted by Congress as part of the Tax Cuts and Jobs Act (TCJA). Procedurally, the § 245A temporary regulations are unique as the first and only post-TCJA regulations to date (1) to be issued by Treasury in temporary form and (2) to invoke the good cause exception, including an extended explanation of Treasury’s reasons for doing so.
Kandyce Korotky (Covington & Burling, Washington; D.C.), Two Steps Forward, Two Steps Back? Good Cause and the Section 245A Temporary Regulations
Steven R. Dixon (Miller & Chevalier, Washington, D.C.), Scrutinizing Treasury’s First Argument for the Good-Cause Exception