On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more
5/26/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
The Internal Revenue Service (IRS) recently published a notice providing the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy production tax credits under Internal Revenue...more
On September 3, 2020, the Internal Revenue Service (IRS) released long-awaited final regulations (Final Regulations) under section 468A of the Internal Revenue Code of 1986, as amended (Code). The Final Regulations generally...more
In the wake of the devastating wildfires that engulfed the State of California in 2019, California enacted legislation, California Assembly Bill 1054, to, amongst other things, authorize the creation of a Wildfire Fund. The...more
In PLR 202020011, the Internal Revenue Service (IRS) reaffirmed that a wind energy facility owned by a utility affiliate and unrelated investor in a LLC taxable as a partnership was not “public utility property” because the...more
On March 6, 2020, the Internal Revenue Service (IRS) released PLR 202010002, which provided the appropriate normalization treatment of infrastructure surcharges in supplemental rate proceedings as well as the proper...more
In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more
In CCA 201928014 (July 12, 2019), the IRS Office of Chief Counsel provides its view of the interplay between the net operating loss (NOL) carryover rules set forth in Internal Revenue Code (Code) § 172(b)(2) and the...more
On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that include guidance on the...more
The Internal Revenue Service (IRS) and the Treasury Department (Treasury) have issued final regulations that address amendments to the rules for discounting unpaid losses pursuant to Section 846 under the Tax Cuts and Jobs...more
6/25/2019
/ Corporate Bonds ,
Corporate Taxes ,
Discounts ,
Final Rules ,
Interest Rates ,
Internal Revenue Code (IRC) ,
IRS ,
NAIC ,
Net Operating Losses ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
On November 6, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued proposed regulations that address amendments to the rules for discounting unpaid losses under section 846 that were enacted...more
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54, which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC § 817(h). This new security, called a...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers. The IDD is the product of a two-year...more
On October 19, the Internal Revenue Service (IRS) issued an advance version of Notice 2016-63, addressing the “reasonable mortality charge” requirement under IRC §§ 7702 and 7702A for life insurance contracts based on the...more
On December 18, 2015, Congress passed and President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (Act), which made several significant amendments to section 831(b) of the Internal Revenue Code....more