The Internal Revenue Service (IRS) recently released IRS Form 15620, Section 83(b) Election (Form 15620), an approved form for taxpayers to use to make a Section 83(b) election. A taxpayer is not required to use Form 15620 to...more
The Treasury Department and IRS on Wednesday issued an eagerly awaited notice of proposed rulemaking to incentivize clean energy facilities: the “clean electricity production credit”—Section 45Y credit—and “clean electricity...more
6/4/2024
/ Clean Energy ,
Energy Storage ,
Greenhouse Gas Emissions ,
Inflation Reduction Act (IRA) ,
Interconnections ,
Internal Revenue Code (IRC) ,
IRS ,
Notice of Proposed Rulemaking (NOPR) ,
Production Tax Credit ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
4/24/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Wallets ,
Internal Revenue Code (IRC) ,
IRS ,
Know Your Customers ,
Reporting Requirements
The Commonwealth of Pennsylvania changed its tax treatment of assistance that employers provide for dependent care services – including dependent care flexible spending accounts. Retroactive to January 1, 2023, Pennsylvania...more
On January 31, 2024, the United States House of Representatives passed the Tax Relief for American Families and Workers Act of 2024 (TRAFW Act), which is now under consideration in the Senate. The TRAFW Act, in addition to...more
The current draft of the Tax Relief for American Families and Workers Act of 2024 includes a proposed provision that would dramatically accelerate the deadline to file claims for the Employee Retention Credit (ERC) to January...more
Summary -
The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more
On August 16, 2022, President Biden signed into law the Inflation Reduction Act (IRA). The IRA made a variety of changes to the Internal Revenue Code (Code). This Alert discusses four of the changes: the one percent excise...more
Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more
8/19/2020
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Private Equity ,
Proposed Regulation ,
Real Estate Investments ,
Tax Cuts and Jobs Act
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
8/14/2020
/ Business Taxes ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Reform
There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.
Internal Revenue Code Section 1231 applies to depreciable property and...more
6/28/2019
/ Capital Gains ,
Community Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning
The Pennsylvania Department of Revenue (the Department) published an Information Notice setting forth its position as to how the repatriation income and deduction under Section 965 of the Internal Revenue Code (the Code) (the...more