Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more
Governor Gavin Newsom said on April 25 that California continued to rapidly add the battery storage that is crucial to the transition to cleaner energy, but admitted it was still not enough to avoid blackouts during heat...more
The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code (the “Code”) to allow taxpayers to sell certain Federal income tax credits....more
It is not uncommon, in the context of a business entity in which a family owns a controlling or substantial interest, for an adviser to encounter intersecting gift and income tax issues. This week’s post will consider one...more
The IRS launched its Inflation Reduction Act (IRA) Pre-Filing Registration Tool in late 2023 for elective (direct) payments under Section 6417 and tax credit transfers under Section 6418 of the Internal Revenue Code....more
The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more
The Inflation Reduction Act of 2022 added Section 6418 to the Internal Revenue Code of 1986, as amended (the “Code”), which allows taxpayers to elect to transfer all or any portion of certain energy tax credits to an...more
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 § 6418 an election that allows eligible taxpayers...more
On June 14, 2023, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed and temporary regulations regarding the transfer elections for certain tax credits available...more
Something’s Wrong- Of late, a not insignificant number of the business owners with whom I’ve been working have raised some concern over whether they are financially prepared for the next stage of their lives. ...more
As covered in our prior alert, the Inflation Reduction Act[2] (IRA) modified and reinstated existing renewable energy credits and enacted new renewable energy credits. The IRA also enacted two novel alternatives to tax equity...more
Through its recent passage of the Infrastructure Investment and Jobs Act (the “Act”), Congress resolved an open question regarding the extent to which cryptocurrency transactions should be subject to information reporting...more
Many of our posts this year have considered some of the unique issues that are presented by a partner’s contribution of property to a partnership, including the application of the “disguised sale” rules. Today, we will...more
In Route 231, LLC v. Commissioner, 117 AFTR 2d 2016-XXXX (4th Cir. 2016), the U.S. Court of Appeals for the Fourth Circuit held that certain funds received by the taxpayer constituted income from the sale of Virginia land...more
Section 6039 of the Internal Revenue Code requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding exercises of incentive stock options...more
The 7520 rate for January 2016 will increase to 2.2%. The January 2016 Applicable Federal Interest Rates can be found... Section 1274.-- Determination of Issue Price in the Case of Certain Debt Instruments Issued...more
Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
Yesterday, the IRS issued proposed regulations that eliminate the “foreign goodwill exception” under the Section 367(d) regulations and also limit the scope of property that is eligible for the so-called “active trade or...more
In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more
On February 25, 2014, the Treasury Department issued final regulations identifying the circumstances in which a substantial risk of forfeiture would exist under Section 83 of the Internal Revenue Code (the “Code”)....more
On November 5, 2013, the Internal Revenue Service (IRS) issued final regulations relating to the transfer or assignment of certain derivative contracts. The final regulations, which are provided as Treas. Reg. § 1.1001-4,...more