JD Supra

Tax Credit Transfers May Have Unexpected State Tax Consequences

One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and ...
The National Law Review

IRS Commences IRC (Internal Revenue Code) Section 409A Audits

We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...
JD Supra

Initial Guidance on Clean Fuel Production Credit Under IRC Section 45Z

On January 10, 2025, the Internal Revenue Service (IRS) issued Notice 2025-10 and Notice 2025-11. Notice 2025-10 summarizes proposed regulations (Proposed Regulations) that Treasury and the IRS plan ...
JD Supra

Treasury Department and IRS Issue Final Regulations Regarding the Clean Electricity Tax Credits Under Sections 45Y and 48E of the Internal Revenue Code

On January 7, 2025, the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations [TD 10024] (Final Regulations) providing guidance on the Clean ...
Wealth Management

What Happens When A Charitable Trust Distributes All Its Assets to a Private Foundation?

IRS Private Letter Ruling 202550004 addresses tax implications when charitable trust distributes all assets to private ...
JD Supra

Navigating IRC Section 280E: Current Updates for Cannabis Taxpayers

With October’s deadline for taxpayers on tax return filing extension for tax year 2024 quickly approaching, this alert provides updates to our post in May on the exploding trend of cannabis tax filers ...
JD Supra

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of ...
JD Supra

OBBBA Impacts on Executive Compensation: Changes to IRC Sections 162(m) and 4960

On July 4, 2025, H.R. 1 — the One Big Beautiful Bill Act (the OBBBA) was enacted into law. OBBBA introduces significant amendments to the Internal Revenue Code (IRC), including notable changes to ...
JD Supra

Treasury and IRS Issue Final Regulations on the Credit for Production of Clean Hydrogen Under Section 45V of the Internal Revenue Code

The final regulations retain the general framework of the proposed regulations, with some important modifications based upon comments from industry members. The acquisition and retirement of energy ...
Wealth Management

Increased Planning Opportunities Using QSBS Exclusions

Paul Lee explores how the One Big Beautiful Bill Act transforms qualified small business stock planning with new limits and ...
JD Supra

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or ...