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Tax Liability Tax Credits

Farrell Fritz, P.C.

Understanding New York State’s STAR Program

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New York State offers the School Tax Relief (STAR) program to provide a bit of property tax relief to eligible homeowners. First, who is eligible? The basic STAR program requires that you own your home, that it is your...more

Kerr Russell

Tax Exempt Entities May be Eligible to Receive Direct Cash Payments of Tax Credits

Kerr Russell on

Section 6417 of the Internal Revenue Code was added by the Inflation Reduction Act of 2022 (IRA). The section provides that eligible taxpayers may make an election to claim certain clean energy credits even though they have...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Paul Hastings LLP

Treasury and IRS Release Final Regulations on Direct Pay

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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

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

Ballard Spahr LLP

House Tax Bill Would Greatly Accelerate Employee Retention Credit Filing Deadlines

Ballard Spahr LLP on

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

Williams Mullen

[Event] Winter Tax Forum 2024 - January 31st, Richmond, VA

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Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more

Bradley Arant Boult Cummings LLP

Blazing Trails: Exploring ESOPs in the Cannabis Industry

The budding cannabis industry, despite its rapid growth and gradual acceptance in recent years, still faces a major sustainability challenge: Cannabis businesses cannot deduct most ordinary business expenses. Under Internal...more

Mayer Brown

Brazilian IRS Clarifies Taxation of Credits Originated from a Court Decision

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On December 19, 2023, the Brazilian IRS published COSIT Answer to Advance Tax Ruling Request No. 308/2023 to clarify the Federal Tax Administration’s position regarding the levy of IRPJ, CSLL, PIS and COFINS on credits...more

Baker Donelson

SALT Select Developments - January 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Lowndes

Too Good To Last? IRS Halts Processing of ERC Claims

Lowndes on

While not as well-known as the Paycheck Protection Program, the Employee Retention Credit (“ERC”) program was another form of Covid relief provided by the federal government to businesses in 2020 and 2021. The ERC program...more

Gray Reed

IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims

Gray Reed on

For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims.  More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

Jones Day on

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Goodwin

The South Korean K-Chips Act and Its Impact on International Companies and Investors

Goodwin on

For investors in enterprises in the Korean semiconductor industry and other national strategic industries, a new tax bill has been passed that (i) increases the base tax credits received by these enterprises to 25% (if...more

Morrison & Foerster LLP

Turning Tax Credits into Cash: IRS and Treasury Release Proposed Direct Pay and Transferability Regulations

On June 14, 2023, the IRS and Treasury Department released proposed regulations regarding the monetization of certain clean energy tax credits, as well as temporary regulations regarding mandatory information and registration...more

Holland & Hart LLP

Top 10 Things to Know: Proposed Regs for Renewable Energy Direct Pay & Direct Transfer

Holland & Hart LLP on

On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more

Mayer Brown

US Treasury to Propose Regulations on Domestic Content Bonus Credit

Mayer Brown on

On May 12, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a notice of intent to issue proposed regulations on the domestic content bonus credit for certain clean energy...more

Brownstein Hyatt Farber Schreck

IRS Releases Long-Awaited Spending Plan for $80 Billion in New Inflation Reduction Act Funding

On Thursday, April 6, the Treasury Department and Internal Revenue Service (IRS) issued their long-term Strategic Operating Plan (SOP), outlining how the IRS intends to spend $79.4 billion in funding provided by the Inflation...more

Mayer Brown

US Treasury Issues Proposed Regulations on Section 30D Clean Vehicle Credit

Mayer Brown on

Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more

Wilson Sonsini Goodrich & Rosati

The IRS Releases Preliminary Guidance on the IRA Energy Community Bonus Credit

On April 4, 2023, the Internal Revenue Service (IRS) released Notice 2023-29 (which follows an earlier notice [Notice 2022-51] released in October 2022 soliciting comments on bonus tax credit requirements) regarding certain...more

McDermott Will & Emery

[Webinar] Going Green: Environmental and Sustainability Risks and Opportunities for Alcohol Companies - April 19th, 12:00 pm -...

In recent years, environmental and sustainability concerns have become increasingly important across the economy. Such concerns create both risks and opportunities for the alcoholic beverages industry. Join our experienced...more

Freeman Law

Tax Court in Brief | Moore v. Comm’r | Research Credit and Computation of Research Expenses under Section 41(a)

Freeman Law on

Summary: Petitioner Gayla Moore was the sole owner of Nevco, Inc. (Nevco), a subchapter S corporation, during the tax years in issue (2014 and 2015). Nevco claimed the section 411 credit for increasing research activities...more

Akin Gump Strauss Hauer & Feld LLP

IRS Publishes Initial Guidance on Section 48C(e) Advanced Energy Project Tax Credit

The Internal Revenue Service (IRS) released its initial guidance (the Advanced Energy Project (AEP) Notice, Notice 2023-18) establishing procedures for taking advantage of the renewed and expanded qualifying advanced energy...more

Stikeman Elliott LLP

Court of Appeal of Québec Confirms Restrictions on the Tax Authorities’ Ability to Set Off Certain Claims in Insolvency...

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On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more

Freeman Law

Tax Court in Brief | Vassiliades v. Comm’r | Deficiency for Disallowed American Opportunity Credit

Freeman Law on

This case involves whether taxpayers are allowed to claim the American Opportunity Credit (AOC) on their federal income tax return. In 2018, the IRS disallowed the AOC claimed by John M. Vassiliades and Eliza Ortizluis...more

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