The U.S. Treasury Department and the Internal Revenue Service (IRS) recently issued proposed regulations providing guidance to taxpayers on the tax consequences of modifying financial instruments and contracts in advance of...more
The Internal Revenue Service recently published its annual notice providing the inflation adjustment factors and reference prices used in determining the amount of production tax credits (PTCs) for renewable energy and...more
Earlier this month, the Internal Revenue Service issued Notice 2019-43, which modifies guidance provided in prior Notices 2013-29, 2013-60, 2014-46, 2015-25, 2016-31, 2017-04 and 2018-59 to provide that the continuity safe...more
Hurricane Harvey caused record-breaking devastation to Texas, followed quickly by Hurricane Irma, one of the strongest Atlantic storms in history, wreaking destruction in the southeastern United States. In the midst of these...more
The Internal Revenue Service and Department of Treasury recently issued final and temporary regulations on income inclusion under Section 50(d) of the Internal Revenue Code as it relates to the tax credit industry. The...more
The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more