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

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

Companies that took advantage of the payroll tax deferral under the Coronavirus Aid, Relief, and Economic Security (CARES) Act should be aware of an IRS position regarding repayment of the
Continue Reading Late Payment of Deferred Payroll Taxes Under CARES Act Could Result in Harsh Consequences

On Sept. 13, 2021, the U.S. House Ways and Means Committee announced a proposal to limit charitable deductions for conservation easement contributions made by partnerships and other passthrough entities. The
Continue Reading House Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities

The IRS has published guidance stating that pre-2018 swaps among Bitcoin, Ether, and Litecoin are not eligible for 1031 tax-free exchange treatment. This means that investors who made swaps among
Continue Reading IRS Says No Tax-Free Exchange Treatment for Swaps of Bitcoin, Ether, and Litecoin