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 ...
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 ...
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

IRS Issues New Guidance For Renewable Energy Tax Credits

The IRS continues to issue guidelines regarding the tax credit provisions of Sections 45Y and 48E of the Internal Revenue Code, as amended (IRC). The latest notice was issued as Notice 2025-42 on Aug.
JD Supra

Avoiding IRS Accuracy Penalties for a Substantial Underpayment of Tax

There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662. As ...
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

IRS Issues Guidance on Alternative Distribution Method for Form 1095-C

As part of the Paperwork Burden Reduction Act, signed into law on December 23, 2024, Internal Revenue Code (IRC) sections 6055(c) and 6056(c) were amended to allow the use of the alternative method ...
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 ...
JD Supra

California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)

Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years ...
JD Supra

Production Tax Credits and Bankruptcy – Are Your PTC Rights at Risk?

The Inflation Reduction Act of 2022 created the ability to transfer production tax credits (“PTC”) to an “eligible taxpayer” pursuant to Section 6418 of the Internal Revenue Code (“IRC”). However, ...