Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more
“Show Me the Money”- Much has been written in recent months about how well the investment portfolios of private foundations have performed over the last several years. For example, a study conducted by the Council on...more
On July 1, 2021, the Internal Revenue Service (IRS) released Revenue Ruling 2021-13 (the Revenue Ruling), addressing the application of section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q) to carbon...more
On January 6, 2021, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) under section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q),...more
On January 6, 2021, the Internal Revenue Service and the Department of the Treasury released final regulations on the IRC section 45Q carbon capture and sequestration (CCS) credit in order to implement changes made to that...more
Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more
Section 45Q, as amended by the Bipartisan Budget Act of 2018 (BBA), provides a substantial tax credit for the capture and sequestration of carbon dioxide and other carbon oxides. Taxpayers have been awaiting guidance from the...more
On May 28, 2020, the Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which provides a credit for the capture...more
The IRS recently amended the rules applicable to hardship distributions from 401(k) and 403(b) plans. The new hardship distribution regulation relaxes some of the restrictions on the availability of hardship distributions...more
The Internal Revenue Service (the “IRS”) issued final regulations, effective September 23, 2019 (the “Final Regulations”), that modify the hardship distribution rules for plans established under Section 401(k) of the Internal...more
The Internal Revenue Service on September 23 finalized proposed regulations relating to hardship distributions under an IRC 401(k) plan. The final regulations differ little from the proposed regulations published on November...more
In February 2018, the tax credit for carbon capture and sequestration under Section 45Q of the Internal Revenue Code (the carbon sequestration credit) received a significant boost from Congress in the Bipartisan Budget Act of...more
On May 2, 2019, the Internal Revenue Service (IRS) released Notice 2019-32 (Notice) requesting comments on anticipated regulations and other guidance under section 45Q of the Internal Revenue Code. Section 45Q was originally...more
On November 14, 2018, the Internal Revenue Service (“IRS”) released Proposed Regulations to implement and expand upon the changes to 401(k) hardship distribution rules, previously mandated by the Bipartisan Budget Act of 2018...more
Otis Redding and the Black Crowes may have proclaimed themselves “hard to handle now,” but thanks to recent guidance from the Internal Revenue Service (IRS), hardship distributions from 401(k) plans are a bit less hard to...more
The IRS has issued proposed regulations affecting hardship distributions under 401(k) plans. The regulations would implement changes made by the Bipartisan Budget Act of 2018, and are updated for several earlier legislative...more
The Bipartisan Budget Act of 2018 (“Budget Act”) includes several changes to the rules governing hardship withdrawals from 401(k) plans. Because the changes apply to plan years beginning after December 31, 2018, 401(k) plan...more
The IRS has issued final regulations under IRC § 6221(b), implementing rules for electing out of the new centralized partnership audit regime enacted under the Bipartisan Budget Act of 2015. The final regulations under IRC §...more
The Bipartisan Budget Act of 2015 fundamentally changes the rules and procedures governing IRS audits of partnerships for taxable years beginning on or after January 1, 2018. These new rules are contained in new Sections...more
The U.S. Bipartisan Budget Act of 2015 amended the provisions of the U.S. Internal Revenue Code of 1986, as amended (Code), governing partnership audit proceedings. The new provisions are designed to simplify the ability of...more