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Close but no cigar: IRS releases updated draft Form 6765 “attempting” to reduce the heightened level of detail required to claim...

On June 21, 2024, the Internal Revenue Service (IRS) released an early draft of revised Form 6765, Credit for Increasing Research Activities. Following the release of the September 2023 draft Form 6765 which dramatically...more

Government updates procedures to change R&D, income recognition, and inventory methods in new Rev. Proc. 2024-23

On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more

A Giant Eagle rematch? IRS Chief Counsel reiterates its disagreement with Third Circuit’s interpretation of all-events test

On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more

A fickle friend: Released on the same day, IRS rulings grant and deny 9100 relief

On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more

Christmas comes early for taxpayer seeking to include construction service costs as part of bonus depreciation eligible investment...

In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

“But wait, there’s more.” – Rev. Proc. 2020-39 provides guidance on the proper treatment of excess deferred taxes, and other...

On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more

Timing is everything – Treasury and IRS propose regulations under Section 451(b)

On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more

Where there’s smoke there’s fire? IRS simplifies income deferral rules with issuance of final regulations to repeal Treas. Reg. §...

On July 11, 2019, the Internal Revenue Service (Service) and Department of Treasury (Treasury) issued final regulations to remove Treas. Reg. § 1.451-5, which allowed taxpayers to delay reporting income with respect to...more

Miracle on Constitution Avenue - IRS releases anticipated method change guidance regarding new income recognition standards under...

On November 29, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-60, which provides automatic accounting method change procedures for taxpayers seeking to comply with section 451(b), relating to the timing of...more

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

Tax planning in the age of tax reform

On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the TCJA), the most substantial overhaul of the Internal Revenue Code since 1986. The TCJA significantly changes how the US taxes individuals,...more

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