News & Analysis as of

Inflation Reduction Act (IRA) Corporate Taxes Internal Revenue Service

Crunched Credit

The Administrative Illuminati in Pursuit of Command and Control (Or the Unmentionable in Hot Pursuit of the Inedible with...

Crunched Credit on

The way we regulate rarely works terribly well for the regulator or the regulated.  Yet, we keep doing it the same way…a subspecies of insanity to be sure.   As an example, has anyone out there in CRE land taken a gander at...more

Vinson & Elkins LLP

Why CAMT I Get Away From You: Losing Applicable Corporation Status Under the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Mayer Brown

Outlook for Energy and Tax Policy in 2025

Mayer Brown on

While we await the outcome of the upcoming US elections, stakeholders in the energy tax and policy space should recognize that, regardless of the outcome of the election, there will be plenty of activity in the energy sector...more

Foodman CPAs & Advisors

Auditoría Comercial Del IRS

El IRS se centra en las empresas desde la aprobación de la Ley de Reducción de la Inflación. Según el Plan Operativo Estratégico (financiado por la Ley de Reducción de la Inflación), el IRS está aumentando las tasas de...more

Foodman CPAs & Advisors

IRS Business Audit

IRS is focused on Businesses since the passage of the Inflation Reduction Act. Under the Strategic Operating Plan (funded by the Inflation Reduction Act), the IRS is increasing audit rates, expanding enforcement and targeting...more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Issue Proposed Regulations Regarding the Stock Buyback Excise Tax

On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more

Allen Barron, Inc.

New Corporate Tax Increase Proposal and Focused IRS Audits - Is the Cost of Business Going Up?

Allen Barron, Inc. on

The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more

Miller Canfield

Leaving on a Jet Plane: Increased IRS Scrutiny on Use of Corporate Aircraft

Miller Canfield on

On February 21, 2024, the IRS announced plans to increase funding under the Inflation Reduction Act to audit the use of corporate aircraft by large corporations, partnerships, and high-income individuals....more

Wilson Sonsini Goodrich & Rosati

Treasury and IRS Release Proposed and Final Regulations on Direct Pay Elections

On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more

Fox Rothschild LLP

Millionaires, Corporate Jets and Crypto: IRS Unveils New Enforcement Initiatives

Fox Rothschild LLP on

Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more

Baker Donelson

IRS Announces Increased Audits on Corporate Jet Usage

Baker Donelson on

The U.S. Internal Revenue Service (IRS) issued a press release on February 21, 2024, announcing its plans to initiate a campaign conducting "dozens of audits" of large corporations and high-income taxpayers, focusing on their...more

Eversheds Sutherland (US) LLP

IRS sees flight risk with corporate jets

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Plans To Increase Audits of Personal Use of Business Aircraft

On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more

McDermott Will & Emery

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

McDermott Will & Emery on

On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more

Eversheds Sutherland (US) LLP

IRS issues transitional guidance regarding reporting and paying the stock buyback tax

On June 29, 2023, the Internal Revenue Service (IRS) issued Announcement 2023-18 (the Announcement), which provides transitional guidance with respect to the stock repurchase excise tax under section 4501 (the Buyback Tax)....more

Levenfeld Pearlstein, LLC

IRS’s Plan Includes Increased Audits for Corporate and High-Income Taxpayers

On April 6, 2023, the Internal Revenue Service released its much-anticipated strategic operating plan. The plan outlines how the agency will use the additional $80 billion in funding from the Inflation Reduction Act. Of...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023

As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022- In 2022 we...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Holland & Knight LLP

Notice 2023-7: First Peek at Corporate AMT Guidance

Holland & Knight LLP on

As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Release Interim Guidance on the One-Percent Excise Tax on Stock Repurchases by Publicly Traded Companies

The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more

Brownstein Hyatt Farber Schreck

Interim Guidance on Book-Minimum Tax and Stock Buyback Excise Tax

The Treasury Department and the Internal Revenue Service (IRS) released initial guidance on Dec. 27, 2022, concerning two corporate tax increases included in the climate and energy reconciliation bill commonly known as the...more

Katten Muchin Rosenman LLP

IRS Issues Guidance on "Qualified Manufacturer" Requirements for New Electric Vehicle Tax Credits

The Inflation Reduction Act of 2022, Public Law 117-169, created three new electric vehicle (EV) tax credits - - the clean vehicle tax credit (Section 30D) for consumers; - the commercial clean vehicle tax credit...more

Venable LLP

IRS Asks for Comment on Whether Existing Fossil-Based Hydrogen Production Methods Should be Eligible for the IRA Production Tax...

Venable LLP on

The Inflation Reduction Act (IRA) contained an enormous benefit - valued in the billions of dollars - for the U.S. hydrogen industry in the form of a Production Tax Credit (PTC) for “qualified” green hydrogen produced over...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, September 13, 2022

LEGISLATIVE LOWDOWN - Recess Recap: What happened over the last month in the world of tax?   Congress Considers Options to Delay Impending Shutdown. With Congress unable to reach a consensus on appropriations bills for...more

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