The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). [1] The modifications ...
On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620, 1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” ...
One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section ...
Clients may be inclined to use a Section 409A valuation for gift tax purposes. After all, both valuations aim to determine ...
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”) ...
On October 17, 2023, the U.S. Internal Revenue Service (IRS) updated its Internal Revenue Manual (IRM) [1] to fully incorporate into the IRM certain e-signature policies and procedures permitting the ...
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several ...
Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, ...
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