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The Code Section 4960 Excise Tax on Excess Executive Compensation – Part I: Tax on Excess Compensation and Potential Tax Mitigation Strategies

The Tax Cuts and Jobs Act (signed into law in late 2017) added Section 4960 to the Internal Revenue Code (“Code”). Code Section 4960 imposes an excise tax (currently 21 percent) on certain excess ...
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New IRS Guidance Regarding Code Section 45Q Credits - Revenue Ruling 2021-13

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 ...
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IRS to Issue Regulations on Effect of Section 67(g) on Certain Deductions for Estates and Nongrantor Trusts

The U.S. Treasury Department and the IRS announced on Friday, July 13, 2018, that they intend to issue regulations on the impact of new section 67(g) of the Internal Revenue Code of 1986 on certain ...
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IRS appears to walk back disregard of certain accounting method changes in proposed section 965 regulations–does it make a difference?

On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the ...
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Employee Benefits: IRS Clarifies and Modifies Code Section 409A Guidance (7/16)

The Internal Revenue Service ("IRS") recently proposed new regulations that are intended to clarify and modify existing IRS guidance regarding the application of Internal Revenue Code section 409A ...
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 ...
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IRS roundup: October 7 – October 23, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025. October ...
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IRS creates a standardized Section 83(b) Election form

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,” ...
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IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included ...
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A New Form Section 83(b) Election: IRS Form 15620

As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) ...
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IRS and Treasury Issue Section 48 Investment Tax Credit Proposed Regulations

Section 48 of the Internal Revenue Code of 1986, as amended (the “Code”) provides for an investment tax credit (“ITC”) for certain energy property. The Inflation Reduction Act of 2022 (the “IRA”) ...
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IRS Issues Proposed Regulations On Section 45Q Carbon Oxide Sequestration Credits

The U.S. Internal Revenue Service (IRS) and the U.S. Treasury Department (“Treasury”) have issued proposed regulations (REG-112339-19) providing valuable guidance on credits for the sequestration of ...