JD Supra

IRS Updates Guidance on Section 530 and Worker Status Issues

IRS Revenue Ruling 2025-3 addresses employment classification disputes for employment tax purposes in five different factual situations. This ruling is specifically concerned with Section 530 of the ...

US Judge Blocks IRS Sharing of Confidential Taxpayer Address Information With ICE

"Plaintiffs have shown that the IRS committed multiple violations of Internal Revenue Code Section 6103(i)(2) when it ...
JD Supra

IRS Provides Initial Guidance on Code Section 48C Qualifying Advanced Energy Project Credit

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 ...
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Section 1256 Contracts: What They Are and How to Report

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 ...
JD Supra

IRS Releases New Section 83(b) Election Form

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 ...
JD Supra

IRS Indefinitely Extends Use of Electronic Signatures for Section 83(b) Elections

On October 17, 2023, the U.S. Internal Revenue Service (IRS) updated its Internal Revenue Manual (IRM) [1] to fully incorporate into the IRM certain e-signature policies and procedures permitting the ...
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How Is IRS Section 1245 Used for Real Estate Taxes?

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 ...
JD Supra

Treasury and IRS Issue Final Regulations on Section 45X

On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) 1 on the Section 45X Advanced ...
JD Supra

Church Inquiries and Examinations by the IRS | A Look at Section 7611 and Its Exceptions

IRS Inquiries and Examinations, Generally – Sections 6201 and 7602. Generally, the IRS is authorized and required by 26 U.S.C. § 6201(a) “to make the inquiries, determinations, and assessments of all ...
JD Supra

It Ain’t Over ‘til It’s Over: IRS reminds Taxpayers That Section 280E Applies to Marijuana Companies Until Rescheduling Becomes Law

This is a tax blog. Stay with me – it’s short. While marijuana advocates celebrate the potential rescheduling of marijuana from Schedule I to Schedule III, the taxman has made clear that marijuana ...
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Use IRS Code Section 1202 to sell your multimillion-dollar startup tax-free

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 ...