A new Internal Revenue Service (IRS) Private Letter Ruling says that transferable development rights (TDRs) are of “like kind” with tangible real property and eligible for 1031 tax deferred treatment

Continue Reading IRS Rules Transferable Development Rights Are Real Property for Section 1031 Purposes

On June 14, 2023, the IRS released proposed and temporary regulations and additional guidance describing rules for eligible taxpayers to benefit from clean energy projects through selling any of the

Continue Reading Proposed Regulations under Section 6418 Transferability of Clean Energy Tax Credits

On June 14, 2023, the IRS released proposed and temporary regulations and additional guidance describing rules for applicable taxpayers to benefit from clean energy projects through electing to receive direct

Continue Reading Proposed Regulations under Section 6417 Direct Pay for Clean Energy Tax Credits

On June 14, 2023, the IRS released proposed regulations and additional guidance describing rules for applicable taxpayers to benefit from investments in renewable energy projects through a direct payment of

Continue Reading IRS Releases Guidance on Elective Payments and Transferability of Certain Tax Credits

The Internal Revenue Service issued proposed regulations on May 31, 2023, for the Low-Income Communities Bonus Credit Program under Section 48(e) of the Internal Revenue Code. The proposed regulations provide

Continue Reading IRS Issues Proposed Regulations for Energy Projects Located in Low-Income Communities

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