Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
Welcome to the latest edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. We pull together the items we deem most important to provide...more
The White House proposed significant budget cuts to the Treasury Inspector General for Tax Administration (TIGTA), reducing its funding by nearly 17% for fiscal year 2027 to the lowest level since 2007....more
Key Takeaways - IRS opens a limited window to reverse prior Section 163(j) elections. Revenue Procedure 2026-17 allows certain real estate businesses to withdraw an otherwise irrevocable election and potentially reclaim bonus...more
Treasury/IRS recently issued Notice 2026-23, which requests recommendations for the 2026-2027 Priority Guidance Plan (PGP). Treasury/IRS use the PGP each year to identify and prioritize the tax issues that they should...more
On January 20, 2026, the Internal Revenue Service reopened its group exemption program with the release of Revenue Procedure 2026-8, ending a multi-year suspension on new group exemption applications. The new guidance...more
Revenue Procedure 2026-17 gives certain taxpayers a limited opportunity to withdraw a previously irrevocable election to be treated as a real property trade or business and to revisit the depreciation consequences that came...more
As companies finalize their 2025 federal income tax returns, taxpayers claiming research credits under Internal Revenue Code § 41 should consider whether the IRS Pre-Filing Agreement (PFA) program can provide advance...more
The Internal Revenue Service (IRS) recently finalized new procedures for section 501(c) organizations to obtain and maintain group exemption letters and, after more than five years of suspension, resumed accepting...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 13, 2026 – January 20, 2026....more
The US Internal Revenue Service released Revenue Procedure 2026-8 on January 15, 2026, updating the procedures required for section 501(c) organizations to obtain and maintain group exemption letters. As of January 20, the...more
The Internal Revenue Service (IRS) issued new rules (Revenue Procedure 2026-08) applicable to group exemptions on January 20, 2026, adding significant compliance requirements for nonprofits that maintain or wish to maintain...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026....more
A manager of a private investment fund may consider employing a management fee waiver strategy, under which the manager waives its management fees in exchange for a profit interest in the fund (typically organized as a...more
The U.S. Department of the Treasury and IRS on Dec. 15, 2025, issued long-awaited final regulations (Regulations) on the Tribal General Welfare Exclusion (GWE) Act of 2014 (the Act). The Regulations mark a major turning point...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 7, 2025 – November 24, 2025. The IRS released Internal Revenue Bulletin No. 2025-46, which includes proposed...more
Revenue Procedure 2025-31 establishes a safe harbor that permits exchange-traded products (ETPs) that are organized as trusts and that hold digital assets on proof‑of‑stake networks to stake those assets without jeopardizing...more
In a favorable development for cryptocurrency investment, the Internal Revenue Service (IRS) issued Revenue Procedure 2025-31. The guidance provides a safe harbor under which certain publicly traded trusts may “stake” their...more
On November 10, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-31 (the Rev. Proc.) which provides a safe harbor which would allow widely held fixed investment trusts to stake digital assets without...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025. October 7, 2025: The IRS issued Notice 2025-55, providing guidance on relief from...more
On August 28, 2025, the Internal Revenue Service (IRS) issued Revenue Procedure 2025-28, providing procedural guidance for taxpayers on the treatment of research and experimental (R&E) expenditures under I.R.C. § 174. ...more
The U.S. government has withdrawn a set of controversial proposed regulations issued near the end of the prior administration, which would have imposed significant new substantive and procedural requirements on taxpayers...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for September 19, 2025 – October 1, 2025. September 19, 2025: The US Department of the Treasury (Treasury) and the IRS...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 28, 2025 – September 15, 2025. August 28, 2025: The IRS issued Revenue Procedure 2025-28, providing guidance on...more
On August 28, 2025, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc. 2025-28 providing procedural guidance for taxpayers seeking to take advantage of the One Big Beautiful Bill...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025. July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for...more