Following their recent announcement regarding new partnership and global high wealth enforcement initiatives, the Internal Revenue Service (IRS) on Oct. 20 announced another enforcement initiative focusing on foreign corporations and the
Continue Reading IRS Ramps Up Enforcement Efforts; Focuses on Foreign-Owned and ‘Mega’ Corporations
On Sept. 14, 2023, the IRS announced an immediate moratorium on the processing of amended returns claiming Employee Retention Credits (ERC). The moratorium, which is set to run through the
Continue Reading IRS Halts Processing of Employee Retention Credit Claims, Announces Initiatives for ERC Claims Filed by Ineligible Businesses
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 Aug. 25, 2023, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations (the Proposed Regulations) regarding the sales or exchanges of digital assets, including
Continue Reading Treasury and IRS Issue New Proposed Regulations on Digital Assets
To address the tax implications for taxpayers who stake cryptocurrency on a proof-of-stake blockchain and receive validation rewards, on July 21 the Internal Revenue Service (IRS) issued Revenue Ruling 2023-14
Continue Reading IRS Clarifies Taxation of Staking Crypto Rewards
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