As Congress shifts into gear on the budget reconciliation process and tax day approaches, there are several key issues for horse owners to keep in mind. In the 119th Congress, there are two proposals that have been...more
4/11/2025
/ Budget Reconciliation ,
Capital Gains ,
Corporate Taxes ,
Depreciation ,
Estate Tax ,
Federal Budget ,
Horse Racing ,
Internal Revenue Code (IRC) ,
Tariffs ,
Tax Deductions ,
Tax Planning ,
US Trade Policies
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more
The U.S. Department of the Treasury and IRS on Oct. 28, 2024, published final regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code (Final Regulations)....more
11/8/2024
/ Energy Projects ,
Energy Sector ,
Final Rules ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Manufacturers ,
Production Tax Credit ,
Suppliers ,
Tax Credits ,
U.S. Treasury
The U.S. Department of the Treasury and IRS on Oct. 24, 2024, released Final Regulations regarding the Section 45X Advanced Manufacturing Production Credit of the Internal Revenue Code. The Final Regulations are effective 60...more
The U.S. Department of the Treasury and IRS on Sept. 19, 2024, released proposed regulations under Section 30C of the Internal Revenue Code providing important clarity on the changes made by the Inflation Reduction Act (IRA)....more
10/8/2024
/ Alternative Fuels ,
Apprenticeships ,
Business Taxes ,
Charging Stations ,
Energy Storage ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Motor Vehicles ,
Prevailing Wages ,
Property Tax ,
Proposed Regulation ,
Public Comment ,
Tax Credits ,
U.S. Treasury
Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more
7/19/2024
/ Administrative Authority ,
Administrative Procedure Act ,
Chevron Deference ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Government Agencies ,
IRS ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
Statute of Limitations ,
Statutory Interpretation ,
U.S. Treasury
The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more
6/27/2024
/ 16th Amendment ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Moore v US ,
Repatriation ,
SCOTUS ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Revenues
Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
6/13/2024
/ Administrative Procedure Act ,
Conservation Easements ,
Corporate Taxes ,
Easements ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Tax Appeals ,
Tax Avoidance ,
Tax Court ,
Tax Penalties ,
Tax Shelters
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
6/3/2024
/ Audits ,
Bipartisan Budget Act ,
Corporate Taxes ,
Default ,
IRS ,
Jurisdiction ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Returns ,
TEFRA
The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more
5/31/2024
/ Anti-Abuse Rule ,
C-Corporation ,
Complex Corporate Transactions ,
Corporate Taxes ,
IRS ,
Real Estate Development ,
Real Estate Transfers ,
Recharacterization ,
Related Parties ,
Tax Court ,
Tax Deferral ,
Tax Planning ,
Tax-Deferred Exchanges
The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business decisions and disrupt...more
The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more
5/17/2024
/ Administrative Procedure ,
Appeals ,
Enforcement Authority ,
Foreign Corporations ,
Foreign Tax ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
Penalties ,
Reporting Requirements ,
Reversal ,
Stare Decisis ,
Statutory Authority ,
Tax Assessment ,
Tax Court
In holding that that Treas. Reg. § 1.170A-14(g)(6)(ii) (Proceeds Regulation) is procedurally invalid under the Administrative Procedure Act (APA), the U.S. Tax Court abandoned its precedent in Oakbrook Land Holdings, LLC v....more
4/5/2024
/ Administrative Procedure Act ,
Chevron Deference ,
Conservation Easements ,
Easements ,
Fair Market Value ,
Gifts ,
IRS ,
Legal History ,
Partnerships ,
Property Valuation ,
Tax Court ,
U.S. Treasury ,
Vesting
A U.S. Tax Court decision entered on Feb. 20, 2024, in 23rd Chelsea Associates LLC v. Commissioner of Internal Revenue held that bond issuance and related financing costs incurred in connection with the development of a...more
3/25/2024
/ Affordable Housing ,
Audits ,
Bond Financing ,
Construction Project ,
General Contractors ,
Housing Developers ,
Internal Revenue Code (IRC) ,
LIHTC ,
Low Income Housing ,
Real Estate Development ,
Tax Court ,
Tax-Exempt Bonds ,
Transaction Fees ,
Union Dues ,
Unions
The U.S. Department of the Treasury and IRS released final regulations under Section 6417 of the Internal Revenue Code, as enacted by the Inflation Reduction Act (IRA). Section 6417 allows certain taxpayers to elect to...more
3/19/2024
/ Cash Value ,
Clean Energy ,
Comment Period ,
Final Rules ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Policies and Procedures ,
Production Tax Credit ,
Tax Credits ,
U.S. Treasury
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more
The second quarter of 2023 saw continued developments as a result of the enactment of the Inflation Reduction Act of 2022 (IRA), court activity and announcements from federal agencies. Below, we summarize the updates you need...more
7/27/2023
/ Energy Projects ,
Energy Sector ,
Energy Tax Incentives ,
Excise Tax ,
Grants ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
NPRM ,
Precedential Opinion ,
Production Tax Credit ,
Renewable Energy ,
Safe Harbors ,
Tax Credits ,
U.S. Treasury
The U.S. Department of the Treasury and IRS on May 31, 2023, released a Notice of Proposed Rulemaking (NPRM) regarding the low-income community bonus credit under Section 48 of the Internal Revenue Code. The NPRM requests...more
The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests. On April 25, 2023, the IRS published interim guidance (the Interim Guidance), effective as of that date, that...more
Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments. ...more
With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules. Under these rules, the default is that the...more
The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information return penalties pursuant to Section...more
The U.S. Department of the Treasury and IRS have released several pieces of guidance regarding the tax incentives for clean vehicles provided under Sections 30D (new clean vehicle credit), 25E (previously owned vehicle...more
4/14/2023
/ Automotive Industry ,
Batteries ,
Comment Period ,
Electric Vehicles ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Lithium Batteries ,
Manufacturers ,
Mineral Extraction ,
NPRM ,
Supply Chain ,
Tax Credits ,
Tax Incentives ,
U.S. Treasury ,
Zero-Emission Vehicles