December 29, 2024
A grant disbursement to a corporation to be used for rent payments following the September 11, 2001 terrorist attacks on the World Trade Center was not excluded from the corporation's gross income. Grants were made to affected businesses with funding provided by the U.S. Department of Housing and Urban Development. The corporation's grant agreement required the corporation to employ a certain number of people in New York City, with a portion of those people employed in lower Manhattan for a period of time. Pursuant to this agreement, the corporation requested a disbursement as reimbursement for rent expenses.
December 16, 2024
President Donald Trump targeted federal hiring, including specific rules for the Internal Revenue Service, and the United States' participation in the global tax framework being developed by the Organisation for Economic Co-operation and Development among his flurry of executive orders signed on the first day of his second term in the Oval Office.
November 02, 2024
The parent corporation of two tiers of controlled foreign corporations (CFCs) with a domestic partnership interposed between the two tiers was not entitled to deemed paid foreign tax credits under
Code Sec. 902 or
Code Sec. 960 for taxes paid or accrued by the lower-tier CFCs owned by the domestic partnership.
Code Sec. 902 did not apply because there was no dividend distribution.
Code Sec. 960 did not apply because the
Code Sec. 951(a) inclusions with respect to the lower-tier CFCs were not taken into account by the domestic corporation.
October 11, 2024
An appeals court affirmed that payments made by an individual taxpayer to his ex-wife did not meet the statutory criteria for deductible alimony. The taxpayer claimed said payments were deductible alimony on his federal tax returns.
September 16, 2024
The Financial Crimes Enforcement Network (FinCEN) has announced that the mandatory beneficial ownership information (BOI) reporting requirement under the Corporate Transparency Act (CTA) is back in effect. Because reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
August 28, 2024
The 2025 cost-of-living adjustments (COLAs) that affect pension plan dollar limitations and other retirement-related provisions have been released by the IRS. In general, many of the pension plan limitations will change for 2025 because the increase in the cost-of-living index due to inflation met the statutory thresholds that trigger their adjustment. However, other limitations will remain unchanged.
August 24, 2024
The leadership of the Senate Finance Committee have issued a discussion draft of bipartisan legislative proposals to make administrative and procedural improvements to the Internal Revenue Service.
July 20, 2024
The Tax Court ruled that IRS Appeals Officers and Team Managers were not "Officers of the United States." Therefore, they did not need to be appointed under the Appointments Clause.
June 17, 2024
The Treasury and IRS in partnership with the Department of Energy (DOE) reported remarkable demand in the initial application period for solar and wind facilities. Within the first 30-day window, the Inflation Reduction Act's Low-income communities Bonus Credit Program received over 46,000 applications for new energy facilities. The applications were either as part of affordable housing or directly benefiting low-income household across the country.guidance, The program allocates 1.8 gigawatts of capacity available through competitive application for the 2023 program across four categories of qualified solar or wind facilities with maximum output of less than five megawatts. The applications for 2024 represent more than four times the total capacity available for the 2023 program.
January 20, 2024
The Internal Revenue Service is looking to improve its customer service metrics as well as improve its technology offerings in the coming tax filing season. Building on the supplemental funding from the Inflation Reduction Act, the IRS has already seen improvements to its phone service and is now looking to improve on it.