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A Comparison of the Energy Tax Changes in the Proposed House and Senate Tax Reform Bills

On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s...more

Ambiguity in the Proposed Section 468A Nuclear Fund Regulations—Sometimes Less Is More

On October 25, 2017, the Internal Revenue Service (IRS) held a public hearing to provide taxpayers with an opportunity to comment on proposed regulations under section 468A of the Internal Revenue Code of 1986, as amended...more

DC Office of Tax and Revenue Launches New QHTC Sales and Use Tax Exemption Application/Pre-Certification Process

On November 1, 2017, the District of Columbia will begin implementing a new sales and use tax exemption application process for Qualified High Technology Companies (QHTCs). Previously, QHTCs could provide sales and use tax...more

The IRS Continues Providing Normalization Guidance - This Time on Both the Consistency and Proration Rules  

On October 13, 2017, the Internal Revenue Service (IRS) issued two private letter rulings (PLR 201741004 and PLR 201741005) that provide further guidance on applying the normalization consistency rules to the inclusion of...more

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor

The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more

IRS Ruling Provides Helpful Guidance on Normalization Proration Rules 

On September 29, 2017, the IRS issued a private letter ruling (PLR 201739001) providing helpful guidance on the application of normalization proration rules for the calculation of accumulated deferred federal income taxes...more

IRS Provides Safe Harbor for Inadvertent Normalization Violations

On September 7, 2017, the IRS issued Revenue Procedure 2017-47, which provides a safe harbor for regulated public utilities for inadvertent or unintentional uses of a practice or procedure that is inconsistent with the...more

Less Is More or More Is More? Differing Regulatory Ethos in the United States and United Kingdom Pose Challenges for Financial...

The United States is poised to usher in an era of decreased regulation of financial institutions while the trend in the United Kingdom maintains relatively robust regulation of the financial services sector in line with...more

IRS Releases Updated Automatic Changes in Methods of Accounting List

On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more

IRS Releases 2017 Section 45 Production Tax Credit Amounts

On April 12, 2017, the Internal Revenue Service (IRS) published the 2017 inflation-adjustment factors and reference prices used in the calculation of renewable energy production tax credits under IRC section 45. That guidance...more

Think Twice: Costs Associated with Regulatory Approval for Corporate Transactions May Be Deductible

Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

IRS Further Updates Beginning of Construction Guidance for Renewable Energy Tax Credits

On December 15, 2016, the Internal Revenue Service (IRS) issued Notice 2017-04, which updates prior guidance regarding the beginning of construction requirement for renewable energy tax credits under IRC sections 45 and 48. ...more

Incentive Compensation for Employees: Instead of Increasing Banks' Bottom Lines, These Arrangements May Increase the Risk of Fines

The New York State Department of Financial Services (DFS) recently issued guidance to regulated banking institutions (Institutions) prohibiting them from implementing incentive-based compensation programs unless these...more

IRS Updates Beginning of Construction Guidance for Renewable Energy Tax Credits Extended by PATH Act

On May 5, 2016, the Internal Revenue Service (IRS) issued Notice 2016-31, which updates prior guidance regarding the beginning of construction requirement for IRC sections 45 and 48 renewable energy tax credits following...more

Sweeping Changes Proposed to Tax Treatment of Related-Party Debt May Impact Private Funds

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would potentially treat related-party debt, in whole or in part, as equity for U.S. tax purposes. The Proposed Regulations generally apply to...more

Michigan’s New Year Resolution: Refund Opportunities Associated with Electronically Accessed Software and Certain Online Services

The Michigan Department of Treasury (Department) issued a Notice announcing that it will no longer impose sales or use tax on certain prewritten computer software accessed electronically and associated online services. The...more

Simplified Partnership Audit Procedures Radically Alter the Federal Income Tax Treatment of Partnerships

On November 2, 2015, President Obama signed the Budget Act of 2015 (the “2015 Budget Act”), which makes significant amendments to the procedural rules governing federal income tax audits and judicial proceedings that apply to...more

11/6/2015  /  Audits , Income Taxes , Partnerships , TEFRA

Are You Continuing Construction? IRS Issues Fourth Renewable Energy Tax Credit Beginning of Construction Notice

On March 11, 2015, the Internal Revenue Service (IRS) issued Notice 2015-25, which provides further guidance to assist renewable energy facility developers and investors in evaluating whether such facilities satisfied the...more

IRS Issues Preliminary Section 529A ABLE Plan Guidance

On March 10, 2015, the Internal Revenue Service released Notice 2015-18, which provides advance notification of a provision that is expected to be included in final regulations to be issued under section 529A of the Internal...more

Are You Really Sure That Construction Began? IRS Issues Third Notice Regarding Renewable Energy Tax Credit Beginning of...

On August 8, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-46, which provides further guidance intended to assist developers and purchasers of renewable energy facilities evaluate whether such facilities...more

IRS Declares 2014 and 2015 as a Transition Period for FATCA Administration and Enforcement and Provides an Additional Six Months...

Pursuant to Notice 2014-33 (the Notice), the IRS announced that it will treat calendar years 2014 and 2015 as a transition period for the administration and enforcement of the due diligence, reporting, and withholding...more

5/9/2014  /  Due Diligence , Enforcement , Extensions , FATCA , FFI , IRS

Virtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other Virtual Currency Transactions

On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of “frequently asked...more

Legal Alert: Energy Tax Reform: Current Updates And What It Means For Companies In The Energy Sector

Energy tax reform has been the subject of three recent, and very significant, administrative and legislative proposals: - The President’s 2015 budget, released on March 4, 2014; - The comprehensive tax reform plan...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

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