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

Treasury Department, IRS Issue Section 45Z Clean Fuel PTC Registration Guidance

The U.S. Department of the Treasury and IRS released Notice 2024-49 on May 31, 2024, regarding the registration requirement and certain other limited guidance under Section 45Z of the Internal Revenue ...
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 ...