The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more
5/15/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Proposed Legislation ,
Renewable Energy ,
SALT ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Legislation ,
Tax Reform
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
The IRS and Treasury on June 3 issued proposed regulations under Sections 45Y and 48E (proposed regulations), which address clean electricity production and investment tax credits, respectively, that generally replace...more
Prompted by congressional scrutiny of the Internal Revenue Service’s (IRS) efforts to root out those abusing lucrative Puerto Rico tax benefits, the agency has committed to devoting more resources to audits of those taking...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more
3/13/2024
/ Energy Projects ,
Grants ,
IRS ,
Loans ,
New Regulations ,
Partnerships ,
Production Tax Credit ,
Registration Requirement ,
Renewable Energy ,
S-Corporation ,
Tax Credits ,
Tax Exempt Entities ,
Tax Returns ,
U.S. Treasury
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
2/23/2024
/ Bitcoin ,
Capital Gains ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
FinTech ,
Income Taxes ,
Indictments ,
IRS ,
Required Forms ,
Tax Evasion ,
Tax Returns ,
Virtual Currency
As covered in our prior alerts, the Inflation Reduction Act enacted new renewable energy credits, including an advanced manufacturing production credit under Section 45X that provides tax credits to domestic producers and...more
Crypto Firms Announce Initiatives in Payments, Mining, DAOs and More -
Recent reports provided details on new developments across the cryptocurrency market...more
The Department of Justice (DOJ), IRS Criminal Investigations (CI) and international tax authorities continue to prosecute tax abuses related to digital asset transactions. In imposing a multiyear prison sentence in a recent...more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and included a mechanism for certain tax credits to increase by a...more
9/18/2023
/ Apprenticeships ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Penalties ,
Prevailing Wages ,
Production Tax Credit ,
Recordkeeping Requirements ,
Renewable Energy ,
Tax Credits ,
U.S. Treasury
The Internal Revenue Service (IRS) and the Department of the Treasury issued a 282 page notice of proposed rulemaking regarding digital assets and broker reporting on Aug. 26 (the Proposed Regulations), nearly two years after...more
9/14/2023
/ Brokers ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Infrastructure Investment and Jobs Act (IIJA) ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
NPRM ,
Payment Processors ,
Popular ,
Public Hearing ,
Reporting Requirements ,
Stablecoins ,
U.S. Treasury
District Court Upholds Tornado Cash Sanctions, DOJ Charges Founders -
On August 17, a Texas federal court found that Tornado Cash, a crypto mixer (which obscures the source of crypto transactions) is an entity that can be...more
8/28/2023
/ Bitcoin ,
Blockchain ,
Central Bank Digital Currency (CBDCs) ,
Conspiracies ,
Criminal Conspiracy ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Department of Justice (DOJ) ,
E-Commerce ,
Enforcement Actions ,
ETFs ,
Hackers ,
Indictments ,
IRS ,
Monetary Authority of Singapore ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Proposed Regulation ,
Singapore ,
Stablecoins ,
U.S. Treasury
In a recent ruling, a California federal judge held that Kraken, an online cryptocurrency exchange program, has to turn over user information to the IRS as a result of a John Doe summons originally served on Kraken in 2021....more
As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits and enacted under § 6418 an election that allows eligible taxpayers...more
As covered in our prior alerts, the Inflation Reduction Act[1] (IRA) modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable...more
On May 12, 2023, the Internal Revenue Service (IRS) issued initial guidance in the form of the Notice that provides taxpayers with preliminary guidance relating to the application of the domestic content bonus requirements...more
As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more
On March 29, the IRS and U.S. Treasury Department (Treasury) published proposed regulations regarding the recently reinstated Superfund chemical taxes (Proposed Regulations) and set a May 28 deadline for comments.
The...more
In the United States, federal tax policy, through federal income tax credits, is one of the primary methods used to effectuate government subsidies for the development of renewable energy technology in the private sector....more
4/3/2023
/ Biden Administration ,
Clean Energy ,
Climate Change ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
Production Tax Credit ,
Renewable Energy ,
Renewable Energy Incentives ,
Tax Credits
Staking Market Launches, ‘Defi Cover’ Data Published, DAO Buys Golf Course
According to a recent press release, MetaMask Institutional, “the web3 wallet for organizations,” has launched its “institutional staking...more
3/27/2023
/ Biden Administration ,
Blockchain ,
Celebrities ,
Central Bank Digital Currency (CBDCs) ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Fraud ,
Hackers ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Russia ,
Securities and Exchange Commission (SEC) ,
Wells Notice
The IRS and Treasury Department announced on March 21, 2023, that they intend to issue guidance providing that certain NFTs qualify as collectibles under Section 408(m) of the Code. The Notice is the first guidance issued by...more
On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more
Key Takeaways -
..A court approved the issuance of a John Doe summons by the IRS to a bank aimed at identifying individuals who are potentially avoiding their income tax obligations relating to cryptocurrency...more
9/29/2022
/ Banks ,
Bitcoin ,
Crypto Exchanges ,
Digital Assets ,
IRS ,
John Doe Investigation ,
Ponzi Scheme ,
Summons ,
Tax Avoidance ,
Tax Liability ,
Tax Returns ,
Virtual Currency
Key Takeaways:
..Recently enacted direct pay and transfer provisions apply to certain clean energy tax credits. These provisions will have a significant impact on how taxpayers can monetize these tax credits and, in...more
9/16/2022
/ Biden Administration ,
Carbon Capture and Sequestration ,
Clean Energy ,
Climate Change ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
Monetization ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits