The U.S. Department of the Treasury and IRS released Notice 2024-49 on May 31, 2024, regarding the registration requirement and certain other limited guidance under Section 45Z of the Internal Revenue ...
The Internal Revenue Service (IRS) recently published final regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to Section 162(m) of the Internal Revenue Code (Section ...
On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620, 1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” ...
The last few years have seen the proliferation of so-called section 643(b) trusts. Although there are various iterations of these trust arrangements, a common purpose seems to permeate each of them: ...
One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section ...
Whoever said you can’t have your cake and eat it too should have called their accountants and lawyers first. These professionals often receive inquiries from founders, equity investment firms and ...
On December 26, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pertaining to the clean hydrogen production ...
Section 1256 contracts include certain regulated futures contracts, foreign currency contracts and non-equity options. These contracts receive a unique tax treatment under the IRS code and are subject ...
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