News & Analysis as of

S-Corporation Tax Credits

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations Regarding the Transferability of Tax Credits Under Section 6418 of the...

The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more

BakerHostetler

Monetizing Renewable Energy Credits - Final Regulations on Direct Pay

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As covered in our prior alerts, the Inflation Reduction Act modified and reinstated existing renewable energy credits, enacted new renewable energy credits, and enacted under § 6417 an election that allows applicable entities...more

Baker Donelson

SALT Select Developments - February 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

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Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Paul Hastings LLP

Treasury and IRS Provide Guidance on Energy Tax Credit Direct Payment Elections

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The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations for Transfer of Energy Credits under IRA

The IRS and Treasury have issued proposed Treasury Regulations concerning the newly enacted Internal Revenue Code section 6418 which allows eligible taxpayers to sell most clean energy tax credits to unrelated third parties...more

Holland & Hart LLP

Top 10 Things to Know: Proposed Regs for Renewable Energy Direct Pay & Direct Transfer

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On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more

BCLP

The Transferability of Tax Credits: the Creation of Secondary Market Under the Inflation Reduction Act

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The Inflation Reduction Act of 2022 (the “IRA”) represents the largest investment in clean energy and climate change in the history of the United States, with over $370 billion of funding to provide tax credits for clean...more

Ballard Spahr LLP

IRS Introduces a Domestic Filing Exception to Schedules K-2 and K-3

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Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more

Greenberg Glusker LLP

California Provides Path to Deduct State Income Tax for Calculating Federal Tax [UPDATED]

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In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Bodman

Michigan Enacts Elective Flow-Through Entity Tax as “SALT Cap Workaround”

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On Monday, December 20, 2021, Michigan Governor Gretchen Whitmer signed House Bill (H.B.) 5376 into law.  H.B. 5376, also referred to as Michigan’s “SALT Cap Workaround,” amends the Michigan Income Tax Act to allow...more

Miller Canfield

Michigan Pass-Through Entity Tax Enacted - Quick Action May Be Needed for 2021

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Michigan Gov. Gretchen Whitmer signed legislation on December 20, 2021, allowing Michigan pass-through entities to elect to pay a newly enacted 4.25% income tax and for the owners of those entities to claim a tax credit...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

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On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Greenberg Glusker LLP

California Provides Path to Deduct State Income Tax for Calculating Federal Tax

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In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

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The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

McGlinchey Stafford

No Partner/S-Corp Shareholder SALT Deduction Limit On Entity Income Taxes

McGlinchey Stafford on

The Internal Revenue Service has announced that it will be issuing proposed regulations clarifying that certain state or local income taxes imposed on and paid by a partnership and/or an S corporation will not be subject to...more

Bradley Arant Boult Cummings LLP

Snapshot: Corporate Income and Franchise Taxes in the USA

How is taxable income determined in your state? To what extent is the state income tax base aligned with the federal income tax base? Alabama levies a corporate income tax on business entities classified as taxable or “C”...more

McDermott Will & Emery

Weekly IRS Roundup September 14 – September 18, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 14, 2020 – September 18, 2020... September 14, 2020: The IRS published final...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Foodman CPAs & Advisors

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

Eversheds Sutherland (US) LLP

LB&I aims new campaigns at taxpayers at home and abroad

On July 19, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced the addition of six compliance campaigns, bringing to 59 the total number of active campaigns. These six...more

McDermott Will & Emery

More IRS “Campaigns?! IRS Announces Six More Examination Campaigns

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On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Foodman CPAs & Advisors

Did you know that IRS is running 35 Campaigns?

In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more

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