Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more
In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more
Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. The fourth quarter of 2022 brought a flurry of energy tax...more
The IRS recently issued Revenue Procedure 2022-19, which permits S corporations to remedy certain inadvertent terminations of S corporation status and invalid elections without having to request a costly Private Letter...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
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
Revenue Procedure 2021-40 amplifies Rev. Proc. 2021-3, 2021-1 IRB 140, which sets forth areas of the Internal Revenue Code (Code) relating to issues on which the Internal Revenue Service (Service) will not issue letter...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of December 28, 2020 – January 8, 2021... December 29, 2020: The IRS released Revenue Procedure...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 27 – 31, 2020. January 27, 2020: The Joint Committee on Taxation released a report...more
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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11–15, 2019. November 11, 2019: The IRS released Delegation Order 30-9 announcing the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 21 – 25, 2019. October 21, 2019: The IRS issued a news release in which it announced the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5 – 9, 2019. ...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17 – 21, 2019. June 18, 2019: The IRS issued a news release noting that it and the US...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 11 – 15, 2019. February 11, 2019: The IRS issued a news release promoting online...more
What do we, as tax professionals, do when we discover (or our clients discover) that a tax election has been inadvertently missed? There may be a solution for some missed elections. Regulations §§ 301.9100-1 through...more
On April 11, 2018, the IRS released Revenue Procedure 2018-26 (“Rev. Proc. 2018-26”), which provides an expansion of the remedial actions available to issuers of tax-advantaged bonds. Specifically Rev. Proc. 2018-26 provides:...more
The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....more
On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more
The election for married couples to elect portability of the Federal Estate Tax Exemption was introduced in late 2010 when the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act (“TRUIRJCA”) was signed...more
The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more
On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more