IRS Internal Revenue Bulletin: I.R.B. 2025-45 Released

The IRS has published its Internal Revenue Bulletin, which provides transitional guidance on filing returns related to specific interest received from loans for passenger vehicles used in trade or ...
JD Supra

Internal Revenue Code Section 162(m): Proposed Regulations

On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the ...

Are You in Danger of Civil Fraud Penalties?

A fraudulent return cannot be fixed by submitting an amended return after the filer commits fraud, which means the best ...
JD Supra

Internal Revenue Code Section 139 Can Permit Some Employers to Make Tax-Free Payments to Employees Affected by Certain Disasters

As summer arrives and many employees return to their normal places of work, it can be easy to overlook the large numbers of employees who will remain unable to return to full-time work, as a result of ...
JD Supra

Are Partner Retirement or Withdrawal Provisions in Governing Documents Subject to Section 409A of the Internal Revenue Code?

Accounting firm M&A deals often involve complex tax issues, and it’s important to understand their implications before undergoing negotiations and diligence so that you aren’t caught off-guard or have ...
JD Supra

Private Lead Service Line Replacement/Internal Revenue Code: U.S. Senate Legislation Introduced to Allow Issuance of Tax-Exempt Bonds for Removal/Replacement

The stated intent of the Flow Act is to facilitate the ability of cities and utilities to issue tax exempt bonds to finance replacement of lead service lines (“LSL”). The sponsors cite United States ...
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Treasury and IRS Issue Proposed Regulations With Respect to Clean Hydrogen Credits Under Sections 45V and 48 of the Internal Revenue Code

On December 22, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) released a notice of proposed rulemaking and notice of public hearing containing proposed regulations ...
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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 ...
The Manila Times

PhoneX Shares May Qualify as Qualified Small Business Stock (QSBS) under Section 1202 of the Internal Revenue Code

PhoneX Holdings, Inc. (OTC: PXHI) today announces to its shareholders that the Company has determined that, based on its current understanding of the applicable provisions of Section 1202 of the ...
JD Supra

International Tax Withholding | Chapter 3 of the Internal Revenue Code

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions ...