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Inflation Reduction Act (IRA) Internal Revenue Service Income Taxes

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

Rivkin Radler LLP on

An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Vinson & Elkins LLP

Tax Law (and Controversy) Under the Trump Administration

Vinson & Elkins LLP on

As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more

Goodwin

2025 Budget Resolution Update: Tax Implications

Goodwin on

On February 13, the House Budget Committee, voting 21-16 along party lines (Republicans in favor and Democrats opposed), passed a 2025 budget resolution. The bill does not expressly reference the Tax Cuts and Jobs Act of 2017...more

Katten Muchin Rosenman LLP

US Treasury and IRS Unveil Proposed Regulations for Commercial EV Tax Credit, Sparking Questions on Recapture Provisions

On January 10, the US Treasury Department (Treasury) and the US Internal Revenue Service (IRS) released proposed regulations under Section 45W of the US Internal Revenue Code of 1986, as amended (the Code), which provides a...more

Bowditch & Dewey

Save on your energy bill and income taxes

Bowditch & Dewey on

It is possible to reduce both your energy bills and your federal income tax through use of the energy tax credit. If you make energy efficient home improvements after January 1, 2023, you may qualify for a tax credit up to...more

Cadwalader, Wickersham & Taft LLP

Should We Address the Big Red Elephant in the Room?

Enacted in August 2022, the Inflation Reduction Act (the “IRA”) expanded energy tax credits by increasing credit amounts across the board and broadening eligibility criteria to include new technologies....more

Eversheds Sutherland (US) LLP

Clarifying the federal tax classification of wholly owned tribal entities and the mechanics of the Section 6417 election for such...

On October 7, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) clarifying the federal tax classification of certain entities wholly owned by...more

Cadwalader, Wickersham & Taft LLP

Treasury and IRS Release Proposed Corporate Alternative Minimum Tax Regulations

On September 13, 2024, in the Federal Register, the Treasury and IRS published proposed regulations implementing the corporate alternative minimum tax (“CAMT”).  Its 182 pages (including 62 pages of preamble) describe a...more

Troutman Pepper Locke

FERC Chief Accountant Proposes to Modify Transferability of Income Tax Credits

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On September 12, 2024, FERC’s Chief Accountant issued a notice of proposed accounting release (“NOPAR”) to modify the transferability of income tax credits (“ITCs”) related to certain energy projects under the Inflation...more

Foodman CPAs & Advisors

High Income High Wealth Taxpayers Pursued By IRS

On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Energy Credits under the Inflation Reduction Act: What do you need to know?

Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

Holland & Knight LLP

Beware: Liberty Global Appeal Puts Basic Tax Planning in Jeopardy

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The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business decisions and disrupt...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Rivkin Radler LLP

An Inveterate Golfer At the IRS

Rivkin Radler LLP on

As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022...more

Pillsbury Winthrop Shaw Pittman LLP

Don’t Forget to File (Accurately): 2024 Brings Heightened IRS and DOJ Focus on Non-Filers and Digital Assets

The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Foodman CPAs & Advisors

Contribuyentes De Altos Ingresos Cuidado Que Las Acciones Del IRS Se Intensifican Si No Se Presentan Declaraciones De Impuestos

El 2/29/24, el IRS anunció un nuevo esfuerzo centrado en los contribuyentes de altos ingresos que no han presentado declaraciones de impuestos federales sobre la renta en más de 125,000 casos desde 2017. Los envíos por correo...more

Foodman CPAs & Advisors

High-Income Taxpayers Beware That IRS Actions Escalate If Tax Returns Aren’t Filed

On 2/29/24, the IRS announced a new effort focused on high-income taxpayers who have failed to file federal income tax returns in more than 125,000 instances since 2017. The mailings include more than 25,000 to those with...more

Troutman Pepper Locke

IRS Issues Final Regulations on Direct Pay

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On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...more

Fox Rothschild LLP

Millionaires, Corporate Jets and Crypto: IRS Unveils New Enforcement Initiatives

Fox Rothschild LLP on

Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more

Eversheds Sutherland (US) LLP

IRS sees flight risk with corporate jets

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Plans To Increase Audits of Personal Use of Business Aircraft

On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more

King & Spalding

IRS and Treasury Issue Section 48 Investment Tax Credit Proposed Regulations

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Section 48 of the Internal Revenue Code of 1986, as amended (the “Code”) provides for an investment tax credit (“ITC”) for certain energy property. The Inflation Reduction Act of 2022 (the “IRA”) amended Section 48 in several...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

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