We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several ...

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 Internal Revenue Service (IRS) issued new guidance regarding Section 45Q tax credits (Revenue Ruling 2021-13). The IRS guidance addresses the application of Section 45Q of the Internal Revenue ...

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 ...

Many people make Section 83(b) elections, named for the subsection of the Internal Revenue Code of 1986 that authorizes them. Simply put, a Section 83(b) election allows taxpayers to include in their ...

On November 7, 2024, the IRS released Form 15620, which can be used by taxpayers to file Section 83(b) elections in connection with transfers of property that are subject to a substantial risk of ...

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 ...

The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). [1] The modifications ...

On November 21, 2025, the IRS released private letter ruling (“PLR”) 202547007, which provides helpful clarification that ...

IRS Section 1245 determines how certain types of property are taxed upon sale. Specifically, it deals with recapturing depreciation on personal property and specific kinds of real estate. When ...

Our Federal Tax Group explains the new standardized Form 15620 that taxpayers can use when receiving property that is subject to a “substantial risk of forfeiture.” Self-drafted election statements ...