News & Analysis as of

Inflation Reduction Act (IRA) Income Taxes Internal Revenue Service

Foodman CPAs & Advisors

High Income High Wealth Taxpayers Pursued By IRS

On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transferability of Energy Credits under the Inflation Reduction Act: What do you need to know?

Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more

McNees Wallace & Nurick LLC

U.S. Treasury Proposes New Regulations on Eligibility Requirements for Clean Energy Tax Credits under the Inflation Reduction Act

The United States Department of the Treasury (Treasury) on June 3, 2024 published proposed regulations on Internal Revenue Code (IRC) Sections 45Y and 48E, which provide for clean energy production and investment tax credits...more

Holland & Knight LLP

Beware: Liberty Global Appeal Puts Basic Tax Planning in Jeopardy

Holland & Knight LLP on

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

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Rivkin Radler LLP

An Inveterate Golfer At the IRS

Rivkin Radler LLP on

As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022...more

Pillsbury Winthrop Shaw Pittman LLP

Don’t Forget to File (Accurately): 2024 Brings Heightened IRS and DOJ Focus on Non-Filers and Digital Assets

The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

Paul Hastings LLP on

The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may make an elective payment, which will treat certain eligible...more

Foodman CPAs & Advisors

Contribuyentes De Altos Ingresos Cuidado Que Las Acciones Del IRS Se Intensifican Si No Se Presentan Declaraciones De Impuestos

El 2/29/24, el IRS anunció un nuevo esfuerzo centrado en los contribuyentes de altos ingresos que no han presentado declaraciones de impuestos federales sobre la renta en más de 125,000 casos desde 2017. Los envíos por correo...more

Foodman CPAs & Advisors

High-Income Taxpayers Beware That IRS Actions Escalate If Tax Returns Aren’t Filed

On 2/29/24, the IRS announced a new effort focused on high-income taxpayers who have failed to file federal income tax returns in more than 125,000 instances since 2017. The mailings include more than 25,000 to those with...more

Troutman Pepper

IRS Issues Final Regulations on Direct Pay

Troutman Pepper on

On March 5, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) on the elective payment of certain tax credits (direct pay) pursuant to Section 6417 of the...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

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

King & Spalding

IRS and Treasury Issue Section 48 Investment Tax Credit Proposed Regulations

King & Spalding on

Section 48 of the Internal Revenue Code of 1986, as amended (the “Code”) provides for an investment tax credit (“ITC”) for certain energy property. The Inflation Reduction Act of 2022 (the “IRA”) amended Section 48 in several...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

Allen Barron, Inc. on

New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Rivkin Radler LLP

Hospitals and Community Benefit: Senators See a Shortfall

Rivkin Radler LLP on

For many weeks, we’ve been hearing about the IRS’s plans to use the funding provided under the Inflation Reduction Act[i] to increase and expand its compliance and enforcement efforts with respect to the wealthy, high-income...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

McDermott Will & Emery

Weekly IRS Roundup September 21 – September 27, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2023 – September 27, 2023...more

Woods Rogers

IRS Announces New Initiatives to Restore Fairness to Tax System

Woods Rogers on

On September 8, 2023, the IRS announced the start of a “sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promotors...more

Polsinelli

IRS Says: New Goal is to Restore Fairness by Using Tax Dollars to Audit More Millionaires, Partnerships and Large Corporations

Polsinelli on

Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...more

ArentFox Schiff

Money (That’s What I Want): IRA’s Direct Pay Mechanism Benefits Tax-Exempt Entities

ArentFox Schiff on

The Inflation Reduction Act (IRA), which recently celebrated its one-year anniversary, presents new opportunities for tax-exempt and other organizations to directly benefit from renewable energy tax credits, including...more

McDermott Will & Emery

Weekly IRS Roundup August 14 – August 18, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 14, 2023 – August 18, 2023...more

Bracewell LLP

Treasury Department and IRS Release Long-Awaited Guidance on Credit Transfers

Bracewell LLP on

On June 14, 2023, the Treasury Department and the Internal Revenue Service (IRS) released long-awaited guidance (the Credit Transfer Guidance) regarding the transfer of energy transition tax credits under Section 6418, which...more

Akin Gump Strauss Hauer & Feld LLP

Proposed Regulations for Low-Income Community Solar/Wind Tax Credit Introduce New Priority Criteria

On May 31, the Treasury Department issued proposed regulations (REG-110412-23) detailing how small solar and wind facilities located in or connected to low-income communities (LIC) can qualify for the so-called Low-Income...more

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