Forbes

Why The IRS Will Continue To Challenge Section 643(b) Trusts

The last few years have seen the proliferation of so-called section 643(b) trusts. Although there are various iterations of these trust arrangements, a common purpose seems to permeate each of them: ...
JD Supra

Can the IRS Assert IRC Section 6676’s Erroneous Refund Penalty on Protective Refund Claims?

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 ...
JD Supra

IRS and Treasury Issue Section 48 Investment Tax Credit Proposed Regulations

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”) ...
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Section 1256 Contracts: What They Are and How to Report

Section 1256 contracts include certain regulated futures contracts, foreign currency contracts and non-equity options. These contracts receive a unique tax treatment under the IRS code and are subject ...
JD Supra

IRS creates a standardized Section 83(b) Election form

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,” ...
JD Supra

IRS Provides Initial Guidance on Code Section 48C Qualifying Advanced Energy Project Credit

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 ...