The Internal Revenue Service issued Notice 2023-17 providing guidance on the Low-Income Communities Bonus Credit Program established under Internal Revenue Code Section 48(e) including environmental justice solar and wind capacity

Continue Reading IRS Releases Guidance on the Low-Income Communities Bonus Credit Program for Solar and Wind Facilities

The Internal Revenue Service issued Notice 2023-18 establishing a program to allocate $10 billion of credits for qualified investments in eligible qualifying advanced energy projects under Internal Revenue Code Section

Continue Reading IRS Establishes a Program to Allocate Credits to Qualifying Advanced Energy Projects

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of

Continue Reading IRS and Treasury Department Finalize Qualified Foreign Pension Funds Regulations

IRS Notice 2023-11 provides temporary relief for foreign financial institutions to provide U.S. taxpayer identification numbers for preexisting accounts.
Continue Reading IRS Temporary Relief for Foreign Financial Institutions Required to Report U.S. Taxpayer Identification Numbers Under FATCA: Potential Implications for ‘Accidental Americans’

The proposed regulations demonstrate that the IRS is taking a proactive approach in addressing the APA challenges to its method for identifying listed transactions. The IRS makes clear that it will continue to aggressively pursue syndicated conservation easement transactions.
Continue Reading Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions