Nearly two months ago, 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...more
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
8/18/2022
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Financial Statements ,
GAAP ,
IFRS ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Rates
On July 27, 2022, the Senate announced agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 (the IRA), the artist formerly known as the Build Back Better Act (the BBBA). Although months ago the...more
Section 446(e) requires a taxpayer to obtain IRS consent prior to changing its accounting method. A change in method of accounting may include either a change in an overall plan of accounting for gross income or deductions...more
On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...more
Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more
9/24/2021
/ Biden Administration ,
Congressional Committees ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Infrastructure ,
IRS ,
Proposed Legislation ,
Reconciliation ,
Research and Development ,
Research and Experiment Tax Credit ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more
In a US District Court complaint filed May 26, 2021, a married couple is seeking a refund of taxes they paid on cryptocurrency tokens the husband created, asserting that current law does not permit the treatment of created...more
6/23/2021
/ Asset Tokens ,
Blockchain ,
Coinbase ,
Cryptocurrency ,
Data Mining ,
Distributed Ledger Technology (DLT) ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Personal Property ,
Popular ,
Reporting Requirements ,
Tax Refunds ,
Token Sales
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
/ Accounting Methods ,
Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
GAAP ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
5/18/2021
/ American Bar Association (ABA) ,
Biden Administration ,
Business Losses ,
Cryptocurrency ,
Financial Reporting ,
Internal Revenue Code (IRC) ,
IRS ,
Legislative Agendas ,
Priority Guidance Plan ,
Section 162(f) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
U.S. Treasury
On April 9, 2021, the Internal Revenue Service (Service) released Chief Counsel Advice 202114020 (the Guidance) regarding the tax consequences to an individual in receipt of Bitcoin Cash (BCH) following the August 2017 hard...more
On Thursday, April 8, the IRS served up Notice 2021-25 (the Notice) providing guidance for taxpayers seeking to take advantage of the temporary 100-percent deduction for the cost of business meals, which was enacted by...more
On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more
Just in time to add to your holiday reading list, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations under sections 451(b) and 451(c) of the Code addressing income...more
On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more
On July 2, 2020, the IRS issued proposed and temporary regulations under section 1502 that implement certain statutory amendments made by the Tax Cuts and Jobs Act (TCJA) and Coronavirus Aid, Relief, and Economic Security Act...more
On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more
On Friday, April 10, 2020, the IRS released Rev. Proc. 2020-22 providing procedural guidance to taxpayers wishing to implement changes made by the CARES Act to the section 163(j) business interest deduction limitation. Under...more
On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more
9/25/2019
/ Bonus Depreciation ,
Commercial Leases ,
Depreciation ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Proposed Legislation ,
Public Utility ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
On September 6, 2019, the Internal Revenue Service (Service) issued Rev. Proc. 2019-37, which grants advance consent to taxpayers seeking to change a method of accounting to comply with the new proposed regulations under...more
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
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
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
On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more