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Revenue Procedures Internal Revenue Code (IRC) Safe Harbors

Freeman Law

Ponzi Schemes and the Theft Loss Deduction

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Every few months or so seem to bring new revelations of a Ponzi scheme gone bust.  In the aftermath, erstwhile investors often struggle to be made whole again.  Fortunately, the federal income tax offers options to help,...more

Mintz - Energy & Sustainability Viewpoints

Viewing Notice 2020-12 Through the Lens of Notice 2013-29 and Notice 2018-59: How is “Beginning of Construction” Guidance for...

In February 2020, the IRS issued Notice 2020-12, which provides long-awaited guidance on when a “qualified facility” or carbon capture equipment, in each case within the meaning of section 45Q, is considered to have “begun...more

Foley & Lardner LLP

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

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On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

Holland & Hart LLP

IRS Publishes Guidance on the Carbon Capture Tax Credit

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On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Issues Anticipated Guidance on Section 45Q Carbon Capture Credits

Further clarity could help unlock much needed investment for a significant number of delayed projects. - After a two-year delay, the IRS finally issues highly anticipated guidance regarding the carbon capture tax credit...more

Akin Gump Strauss Hauer & Feld LLP

Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors

The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more

Morgan Lewis

IRS Releases Critical Guidance on Carbon Capture Tax Credits

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The guidance issued on February 19 by the Internal Revenue Service is the type that the carbon capture and storage industry had sought, and will hopefully open up the market for investment by eliminating tax-related...more

Eversheds Sutherland (US) LLP

Section 45Q Guidance Released

On February 19, 2020, the Internal Revenue Service and the Department of Treasury released the first two pieces of guidance regarding the I.R.C. section 45Q carbon capture and sequestration credit in order to implement...more

McDermott Will & Emery

IRS Issues Private Letter Ruling Allowing Tax Equity Financing with a Regulated Utility Taxpayer

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In Private Letter Ruling 201946007, the Internal Revenue Service (IRS) allowed a tax equity investor to participate with a regulated utility in a tax equity financing arrangement for wind investments without being subject to...more

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

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As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Whitman Legal Solutions, LLC

Revenue Procedure 2019-38 and the Rental Real Estate Safe Harbor under Section 199A

Self-employment creates additional challenges from an income tax perspective. Self-employed individuals must keep careful track of their business expenses so they can properly compute their income. For a professional...more

Miles & Stockbridge P.C.

IRS Finalizes Rental Real Estate Qualified Trade or Business Deduction Safe Harbor

Certain rental real estate owners are likely resting more comfortably knowing that they may take certain deductions from their federal taxes due to the IRS’ recent finalization of its earlier proposed Revenue Procedure. This...more

McDermott Will & Emery

Weekly IRS Roundup July 22 – 26, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22–26, 2019. July 22, 2019: The IRS issued a revenue procedure in which it issued indexing...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – 12, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8 – 12, 2019. April 8, 2019: The IRS issued a news release warning taxpayers against...more

Sands Anderson PC

Tax Reform: Section 199A Qualified Business Income Deduction – Safe Harbor for Rental Real Estate Businesses

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The Internal Revenue Code (“IRC”) Section 199A Qualified Business Income Deduction (“QBI Deduction”) generally provides a 20% deduction (or reduction) of a taxpayer’s qualified net business income received from a pass-through...more

Foley & Lardner LLP

An Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

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In the past few years, the IRS has changed its guidance on whether “management contracts” result in private business use for purposes of the restrictions on use of property financed with tax-exempt bonds. This update...more

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