What is “monetization”? Monetization is the process by which property is converted into money or something else of value. In the context of the Inflation Reduction Act of 2022 (IRA), certain provisions can allow entities that...more
9/25/2024
/ Energy Projects ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Monetization ,
Production Tax Credit ,
Renewable Energy ,
Tax Credits ,
Tax Exempt Entities ,
Tax Incentives ,
Tax Liability
What is the Low-Income Communities Bonus Credit? The Low-Income Communities Bonus Credit available through the Inflation Reduction Act of 2022 (IRA) is designed to increase the siting of, and access to renewable energy...more
9/19/2024
/ Clean Energy ,
Competitive Bidding ,
Economic Development ,
Energy Projects ,
Energy Sector ,
Housing Developers ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
Wind Power
What is the purpose of the Energy Community Bonus Credit? The Inflation Reduction Act (IRA) introduced the Energy Community Bonus Credit to encourage renewable energy project developers to locate their facilities and energy...more
9/11/2024
/ Brownfield Properties ,
Clean Energy ,
Department of Energy (DOE) ,
Energy Projects ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
NAICS ,
Prevailing Wages ,
Production Tax Credit ,
Tax Credits
What is the purpose of the Domestic Content Bonus Credit? The Inflation Reduction Act (IRA) introduced the Domestic Content Bonus Credit to provide an additional credit amount to taxpayers that meet its requirements. The...more
9/9/2024
/ Clean Energy ,
Domestic Corporations ,
Energy Projects ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Renewable Energy ,
Supply Chain ,
Tax Credits ,
Tax Incentives
Why did Congress provide bonus credits to a facility or a project that pays its workers “prevailing wages” and hires apprentices? Congress viewed the Inflation Reduction Act (IRA) as a way to not only move the United States...more
9/3/2024
/ Apprenticeships ,
Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Prevailing Wages ,
Production Tax Credit ,
Tax Credits ,
Tax Incentives ,
Wage and Hour
Why did the Inflation Reduction Act (IRA) reduce the base amounts of the energy tax credits? The IRA reduced base credit amounts from their pre-IRA levels to encourage energy projects to meet Congressional policy objectives....more
8/28/2024
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Investment Tax Credits ,
IRS ,
Prevailing Wages ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
Tax Incentives ,
Wind Power
What is a Production Tax Credit (PTC)?
A Production Tax Credit (PTC) is a per kilowatt-hour (kWh) tax credit for electricity generated by solar and other qualifying clean technologies for the first 10 years of a system’s...more
8/27/2024
/ Carbon Emissions ,
Clean Energy ,
Energy Projects ,
Energy Sector ,
Greenhouse Gas Emissions ,
Hydrogen Power ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Solar Energy ,
Supply Chain ,
Tax Credits ,
Tax Incentives ,
Wind Farm
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
6/12/2024
/ Capital Assets ,
Capital Gains ,
Capital Losses ,
Financial Transactions ,
Foreign Currency ,
Foreign Entities ,
Hedges ,
Hedging ,
Internal Revenue Code (IRC) ,
IRS ,
Securities ,
Tax Planning
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
6/5/2024
/ Capital Assets ,
Capital Gains ,
Capital Losses ,
Financial Transactions ,
Foreign Currency ,
Foreign Entities ,
Hedges ,
Hedging ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Planning
Which transactions qualify as section 988 transactions?
In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Taxpayers can receive significant tax benefits when donating cryptocurrency and other appreciated digital assets to a charity. This article looks at some key considerations to keep in mind as you consider all your options....more
Charities should address several issues when considering whether to accept donations of digital assets, defined to include cryptocurrency, stablecoins, and non-fungible tokens (NFTs)....more
11/15/2023
/ Capital Assets ,
Charitable Donations ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Donations ,
Donors ,
Gifts ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Stablecoins
Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more
Taxpayers can take a tax deduction with respect to “theft” losses that result from an illegal “taking of property” done with criminal intent. Among various other types of criminal activities, fraud is treated as theft under...more
10/11/2023
/ Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Extortion ,
Fraud ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Phishing Scams ,
Ponzi Scheme ,
Ransomware ,
Safe Harbors ,
Scams ,
Tax Deductions ,
Tax Losses ,
Theft
Introduction Until Notice 2023-27, the Internal Revenue Service (IRS) was silent about the tax treatment of nonfungible tokens (NFTs). When the IRS turned to NFTs, it focused on one aspect of NFTs: whether certain NFTs should...more
When taxpayers sell digital assets at a loss, their tax loss is quite straightforward. Their loss equals the amount that their tax basis exceeds the amount they received for the sale. This is not the only way for a taxpayer...more
We’re seeing an increasing variety of digital tokens that represent rights to, interests in, or ownership of an entity. We’re also seeing digital tokens that represent debt obligations of corporations. These tokens can be...more
The taxation of non-fungible tokens (NFTs) is still something of a mystery. All we have to go on is the IRS definition of digital assets and Notice 2023-27. The IRS digital asset definition includes NFTs, stating that they...more
A taxpayer’s investment losses, including losses on digital assets such as cryptocurrencies and non-fungible tokens (NFTs), are not deductible unless the taxpayer’s activities rise to the level of “investment activities” or...more
Until very recently, the IRS has been silent about the tax treatment of non-fungible tokens (NFTs). An almost unknown market in 2020, NFTs skyrocketed to prominence in 2021 with a capitalization at the beginning of 2021 of...more
The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more
3/22/2023
/ Anti-Abuse Rule ,
Asset Management ,
Derivatives ,
Financial Products ,
Internal Revenue Code (IRC) ,
Investment ,
Investors ,
IRS ,
Tax Liability ,
Tax Planning ,
Wash Sale Rules
You need to consider how you’ll report digital asset transactions on your 2022 tax returns. Tax reporting requirements for digital assets have changed yearly since 2019, when the IRS first added a question about crypto to IRS...more
3/21/2023
/ Bitcoin ,
Cryptocurrency ,
Digital Assets ,
Financial Planning ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Products ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Stablecoins ,
Tax Liability ,
Tax Planning ,
Virtual Currency
When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more
Explosive growth in digital assets has left investors with real questions about how to donate cryptocurrency and non-fungible tokens. That the tax bills are high enough to generate this interest is clear evidence of the gains...more
3/6/2023
/ 501(c)(3) ,
Charitable Donations ,
Cryptocurrency ,
Digital Assets ,
Donor-Advised Funds (DAFs) ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Tax Deductions ,
Tax Incentives ,
Tax Planning