Moving intellectual property between owners and entities may sound simple and routine, but there are a few deceptive tax pitfalls that may arise. For transfers of IP involving entities under common ...

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 ...

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 ...

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 ...

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.

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 ...

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 ...

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 ...

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 ...

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 ...