On January 14, 2021, the IRS released final regulations (T.D. 9946) (the “Final Regulations”) interpreting Sections 162(f) and 6050X of the Internal Revenue Code of 1986 (the “Code”), as amended and drafted by the Tax Cuts and Jobs Act (“TCJA”), respectively. As described below, the Final Regulations deviate from and clarify proposed regulations that the IRS issued in May of 2020 (the “Proposed Regulations”) in several important ways. The Final Regulations will apply to taxable years beginning on or after January 14, 2021.

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