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 4, the Internal Revenue Service issued Notice 2023-29 (the Notice), which describes certain rules the IRS intends to include in proposed regulations for qualifying for the energy community

Continue Reading IRS Issues Guidance for Developers, Investors Seeking to Qualify for Energy Community Bonus Credits Under Inflation Reduction Act

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 applicable penalty for the non-willful failure to file a foreign financial account is applied on a per-form basis, not a per-account basis, the U.S. Supreme Court decided Feb. 28

Continue Reading Non-Willful Failure to File FBAR Under BSA Should Be Penalized on a Per-Report Basis, Supreme Court Rules for Taxpayer Against IRS

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