The Internal Revenue Service announced on Sept. 14, 2023, an immediate moratorium on the processing of Employee Retention Credit (ERC) claims that is anticipated to last at least through the end of the year....more
The CARES Act permits employers to defer the deposit and payment of the employer’s portion of social security taxes that otherwise would be due between March 27, 2020, and Dec. 31, 2020. The law permits employers instead to...more
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
On Dec. 13, 2018, the Internal Revenue Service and Department of Treasury issued proposed regulations addressing the base erosion and anti-abuse tax (BEAT). In general, the regulations provide guidance for identifying an...more
On August 8, the Internal Revenue Service (IRS) and the Department of the Treasury released proposed regulations on new section 199A, the 20 percent deduction for qualified business income, added to the Internal Revenue Code...more
Last week, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations concerning the designation and authority of a partnership representative under the centralized partnership audit regime...more
The recent enactment of the Bipartisan Budget Act of 2018 extended and significantly expanded the existing tax credit for carbon sequestration under Section 45Q of the Internal Revenue Code. Although the Section 45Q credit...more
On June 22, the IRS issued Notice 2018-59, providing guidance to determine when construction has begun on energy facilities, for purposes of the Section 48 investment tax credit.
The long-awaited guidance follows changes...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
On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more
On November 2, President Obama signed the Bipartisan Budget Act of 2015 into law, which brought sweeping changes to the partnership audit rules. The act repeals the substantive tax provisions and voluntary centralized audit...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