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: ...

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 ...

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”) ...

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 ...

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 ...