Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more
On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer’s receipt of interests in a partnership in exchange for services rendered to the sole owner of the...more
In recently issued Rev. Proc. 2023-15, the IRS provides a safe harbor method of accounting under which taxpayers may classify costs to repair, maintain, replace, or improve natural gas transmission and distribution property...more
On March 27, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued much anticipated proposed regulations, REG-105954-22 (Proposed Regulations), and additional guidance in the form of Revenue...more
The IRS recently issued Revenue Procedure 2022-19 (“Rev. Proc. 2022-19” or “the Revenue Procedure”), offering taxpayers clarification and new simplified procedures for resolving certain issues related to S corporation...more
At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more
As this nation prepared to celebrate the Independence Day long weekend, many were preparing for the July 1, 2022, reinstatement of the Superfund chemicals tax (the Superfund Tax). The Superfund Tax is an excise tax imposed on...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 27, 2022 to April 2, 2022... March 29, 2022: The IRS issued a news release reminding...more
On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more
The Internal Revenue Service issues three Revenue Procedures detailing how taxpayers can account for tax-exempt cancellation of indebtedness income arising from forgiven Paycheck Protection Program loans in their Federal tax...more
The IRS recently issued guidance on the utility of and weight to be afforded informal “frequently asked questions” (FAQs) published on its website—clarifications that became necessary given the IRS’s heavy reliance on FAQs as...more
The Internal Revenue Service released helpful guidance in Revenue Ruling 2021-13, regarding the scope of carbon capture equipment and the requirement that a taxpayer own the carbon capture equipment to qualify for carbon...more
The Internal Revenue Service has updated the Employee Plans Compliance Resolution System (EPCRS) in several respects that will be helpful to retirement plan sponsors. Revenue Procedure 2021-30, published July 16, 2021,...more
The IRS recently released helpful guidance in Revenue Procedure 2020-44 to assist the market’s transition from the London Interbank Offered Rate (LIBOR) and other interbank offered rates (IBORs) to alternative reference...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 17, 2020 – August 21, 2020... August 19, 2020: The IRS requested comments from large...more
On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more
The Internal Revenue Service (IRS) issued a proposed revenue procedure on group rulings that includes significant changes to the existing procedures under Rev. Proc. 80-27 and substantially restricts eligibility for group...more
On April 8, 2020, the IRS released Revenue Procedure 2020-23 (the Revenue Procedure), which provides guidance for partnerships subject to the centralized partnership audit regime under the Bipartisan Budget Act of 2015 (the...more
On May 4, 2020, the IRS issued Revenue Procedure 2020-19, which temporarily allows a publicly-offered REIT or RIC to pay as much as 90% of a distribution in its own stock (rather than cash or other property) and still have...more
On April 9, we published an article, Global Tax Implications of COVID-19 on Stranded Cross-Border Workers and Multinational Companies, that discussed the analysis released by the Organization for Economic Cooperation and...more
Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...more
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
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
The IRS’s much anticipated new guidance for Section 45Q carbon sequestration tax credits was rather anticlimactic in that it focused on just two of the many issues for which the IRS had solicited comments in May 2019. Largely...more