On May 31, 2023, the IRS released Notice 2023-44, which provides additional guidance for applicants seeking allocations of the Qualifying Advanced Energy Project Credit under Section 48C of the

Continue Reading IRS Provides Additional Guidance for Advanced Energy Projects Under Section 48C of the Code

In Polselli v. IRS, the Supreme Court was tasked with determining whether the IRS, pursuant to powers granted in Internal Revenue Code (IRC) section 7609(c)(2)(D)(i), is entitled to issue third-party summonses, without notice, for bank account records in which the taxpayer targeted by the summons does not have a legal interest.
Continue Reading Supreme Court Affirms IRS Power to Summons Bank Information Without Notice to Delinquent Taxpayer

On April 10, 2023, the U.S. Treasury Department issued proposed regulations identifying certain micro-captive transactions as listed transactions or transactions of interest for purposes of the disclosure rules for taxpayers

Continue Reading IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision

On April 3, 2023, the U.S. Tax Court ruled in Farhy v. Commissioner[1] that the IRS lacks statutory authority to assess Form 5471 penalties under I.R.C. § 6038(b)(1) or

Continue Reading IRS Lacks Statutory Authority to Assess International Information Return Penalties: U.S. Tax Court

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