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22 Jun 2023, 10:00 pm
On June 14, 2023, the Internal Revenue Service and US Department of the Treasury released temporary regulations and proposed regulations (collectively, the Transferability Guidance) relating to the transfer of certain clean technology industry federal income tax credits pursuant to Section 6418 of the Internal Revenue Code of 1986, as amended, which was enacted under the Inflation Reduction Act of 2022. [read post]
24 Jan 2024, 10:00 pm
Partners Casey August, Douglas Hastings, Kenneth Kulak, and Mark Lazaroff, and associates Andreas Andrews and Jared Sanders co-authored a Law360 Expert Analysis discussing the US Department of the Treasury and the Internal Revenue Service’s proposed regulations for the clean hydrogen tax credits under Sections 45V and 48 of the Internal Revenue Code, as enacted by the Inflation Reduction Act. [read post]
12 Jan 2023, 10:00 pm
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. [read post]
22 May 2023, 10:00 pm
The SECURE 2.0 Act of 2022 (SECURE 2.0) made a number of changes in law intended to simplify the administration of retirement plans, including through the expansion of the Internal Revenue Service (IRS) Employee Plans Compliance Resolution System (EPCRS). [read post]
6 May 2015, 11:47 am
On May 5, 2015, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations that provide much-anticipated guidance on the scope of qualifying income under Section 7704(d)(1)(E) of the Internal Revenue Code (Code) for master limited partnerships (MLPs) engaged in activities with respect to minerals or natural resources. [read post]
24 Feb 2021, 10:00 pm
As we described in our LawFlash from last spring, the US Department of Labor’s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service (IRS) (collectively, the Agencies) issued EBSA Notice 2020-01 and a joint final rule (collectively, Guidance) suspending certain deadlines under the Employee Retirement Income Securities Act of 1974, as amended (ERISA) and the Internal Revenue Code of 1986, as amended (Code). [read post]
27 May 2010, 10:09 pm
July 22, 2010 is the deadline for non-profit hospital organizations and other concerned persons to share comments with the Internal Revenue Service (IRS) on the proper construction and application of additional requirements imposed under new Internal Revenue Code (Code) § 501(r)(1) requires that “hospital organizations” meet to qualify as tax-exempt charitable entities added by the Patient Protection and Affordable Care Act. [read post]
14 Sep 2015, 12:15 pm
On September 11, 2015, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) addressing MLP qualifying income. [read post]
4 Feb 2024, 10:00 pm
The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit parental support. [read post]
11 Jan 2021, 10:00 pm
The US Department of Treasury and the Internal Revenue Service released anticipated final regulations pertaining to the federal income tax credit for carbon capture projects under Section 45Q of the Internal Revenue Code on January 6, 2021. [read post]
29 Oct 2014, 12:01 pm
The Internal Revenue Service (IRS) has published the following tax rule relief under the Internal Revenue Code (Code) Notice 2014-65 designates the Ebola virus outbreak occurring in the West African countries of Guinea, Liberia, and Sierra Leone as a qualified disaster for purposes of section 139 of the Code. [read post]
12 Jan 2023, 10:00 pm
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. [read post]
4 Feb 2024, 10:00 pm
The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit parental support. [read post]
22 Jun 2023, 10:00 pm
On June 14, 2023, the Internal Revenue Service and US Department of the Treasury released temporary regulations and proposed regulations (collectively, the Transferability Guidance) relating to the transfer of certain clean technology industry federal income tax credits pursuant to Section 6418 of the Internal Revenue Code of 1986, as amended, which was enacted under the Inflation Reduction Act of 2022. [read post]
11 Jan 2021, 10:00 pm
The US Department of Treasury and the Internal Revenue Service released anticipated final regulations pertaining to the federal income tax credit for carbon capture projects under Section 45Q of the Internal Revenue Code on January 6, 2021. [read post]
25 Jun 2021, 2:29 pm
In a recently-released Memorandum, the Internal Revenue Service (IRS) Office of Chief Counsel stated the agency’s position that certain transactions involving Bitcoin, Ether and Litecoin do not qualify as like-kind exchanges under Section 1031 of the Internal Revenue Code. [read post]
24 Jan 2024, 10:00 pm
Partners Casey August, Douglas Hastings, Kenneth Kulak, and Mark Lazaroff, and associates Andreas Andrews and Jared Sanders co-authored a Law360 Expert Analysis discussing the US Department of the Treasury and the Internal Revenue Service’s proposed regulations for the clean hydrogen tax credits under Sections 45V and 48 of the Internal Revenue Code, as enacted by the Inflation Reduction Act. [read post]
9 May 2022, 10:00 pm
In late March 2022, the US Internal Revenue Service withdrew regulations proposed in 2019 and issued new proposed regulations under sections 413(c) and (e) of the Internal Revenue Code, which provide for an exception to section 413’s “unified plan rule”—commonly referred to as the “one-bad-apple rule”—for multiple employer and pooled employer plans. [read post]
22 Nov 2016, 9:03 pm
Health care organizations sponsoring tax-qualified employee benefit plans or operating as tax-exempt entities under the Internal Revenue (Code) should expect changes in the practices Internal Revenue Service (IRS) agents use to issue and enforce document requests (IDRs) in connection with an IRS audit or other investigation of their employee benefit plans’ tax status or compliance after March 1, 2017. [read post]
4 Jan 2024, 10:00 pm
The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) recently published proposed regulations (Proposed Regulations) setting forth rules applicable to the credit for the production of clean hydrogen and the election to treat clean hydrogen production facilities as energy property under Sections 45V and 48(a)(15) of the Internal Revenue Code (Code) enacted under the Inflation Reduction Act of 2022 (IRA). [read post]
