Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
3/11/2025
/ Compliance ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Regulatory Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly...more
Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more
Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more
Find this week’s updates on 340B litigation to help you stay in the know on how 340B cases are developing across the country. Each week we comb through the dockets of more than 50 340B cases to provide you with a quick...more
2/27/2024
/ Department of Health and Human Services (HHS) ,
Dispute Resolution ,
Drug Pricing ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Healthcare Facilities ,
HRSA ,
Medicare ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Section 340B
The Internal Revenue Service (IRS) released a fact sheet, providing guidance on acceptable methods for taxpayers to electronically or digitally sign certain paper forms that they cannot file electronically. In order to...more
The US Tax Court determined that a pharmaceutical manufacturer’s legal expenses incurred to defend against a patent infringement suit were eligible for an immediate deduction as ordinary and necessary business expenses, while...more
US Senate Finance Committee Chairman Ron Wyden (D-OR) introduced the Clean Energy for America Act (the Act), along with two dozen Democratic co-sponsors, on April 21, 2021. The Act will likely be a starting point for the...more
The Biden Administration has requested a $1.2 billion increase in funding for the Internal Revenue Service (IRS) as part of its proposal for Fiscal Year 2022 (FY 2022) discretionary funding released in a letter from Office of...more
The New Markets Tax Credit (NMTC) program was extended through 2025 with a $5 billion annual appropriation as part of the Consolidated Appropriations Act, 2021, signed by President Trump on December 28, 2020. Before the...more
On September 4, 2020, the Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) published in the Federal Register final regulations under section 468A of the Internal Revenue Code (the Code) that...more
?In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the use of private foundations for tax planning. Ms. Tamera Ripperda, who is the...more
As part of its ongoing response to COVID-19, the Internal Revenue Service (IRS) released Notice 2020-49, which extends certain time criteria related to the New Markets Tax Credit (NMTC) program. Under the notice, any due...more
The Treasury Department and IRS recently published proposed regulations implementing the Section 45Q carbon capture and sequestration credit. The regulations clarify some questions about the credit, though many questions...more
6/16/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Market ,
Energy Sector ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Proposed Regulation ,
Proposed Rules ,
Tax Credits ,
Tax Planning ,
Webinars
A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency.
In Howe...more
In general, section 6751 requires that a supervisor give written approval before penalties can be asserted against a taxpayer. In Koh v. Commissioner, T.C. Memo. 2020-77, authored by the US Tax Court’s (Tax Court) most recent...more
The Internal Revenue Service (IRS) has released a long-awaited proposed rule to implement section 45Q of the Internal Revenue Code, the statutory provision that creates a tax credit for capturing and sequestering carbon...more
In response to a series of questions posed in a November 2019 letter from Senator Menendez (D-NJ), the Treasury Inspector General for Tax Administration (TIGTA) issued a letter on April 15, 2020, analyzing carbon oxide...more
On April 21, 2020, the Internal Revenue Service released an FAQ and two revenue procedures addressing concerns that travel disruptions related to the Coronavirus (COVID-19) pandemic could result in unexpected US tax exposure....more
In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would...more
Recently, the US Federal District Court for the Southern District of Iowa in Meredith Corp. v. United States, No. 4:17-cv-00385 (S.D. Iowa Mar. 20, 2020), held that a magazine publisher was entitled to refund of federal...more
The Internal Revenue Service released a Q&A on Notice 2020-18 to clarify the relief available to taxpayers during the Coronavirus (COVID-19) pandemic. The Q&A offers important new details on the federal income tax filing and...more
3/28/2020
/ Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
Employee Contributions ,
Estate Tax ,
Filing Deadlines ,
Gift Tax ,
Income Taxes ,
Installment Agreements ,
IRS ,
Relief Measures ,
Shareholders ,
Tax Returns ,
Time Extensions
On March 20, 2020, the Internal Revenue Service expanded its relief for taxpayers in light of the Coronavirus (COVID-19) pandemic. All federal income tax payments and federal income tax returns that were due April 15, 2020,...more
President Trump signed into law on Wednesday night the Families First Coronavirus Response Act (the “Act”) following a 90-8 vote by the Senate earlier in the day. The Act provides paid sick leave to American workers affected...more
3/20/2020
/ Coronavirus/COVID-19 ,
Emergency Response ,
Employer Responsibilities ,
Families First Coronavirus Response Act (FFCRA) ,
Family and Medical Leave Act (FMLA) ,
Medical Testing ,
New Legislation ,
Paid Leave ,
School Lunch Programs ,
Sick Leave ,
SNAP Program ,
State of Emergency ,
Unemployment Benefits
Treasury and the IRS released initial guidance on the amended Section 45Q carbon oxide sequestration credit on February 19, 2020. Notice 2020-12 and Revenue Procedure 2020-12 provide guidance relating to the beginning of...more