Key Takeaways
- Inflation Reduction Act
- Research Credit Update
- TCJA
- Blogs and Bits
- National Ice Cream Soda Day
Inflation Reduction Act
Treasury Finalizes Labor Rules For Bonus Energy Tax Credits - Kat Lucero, Law360($):
The 354 pages of rules enact strict recordkeeping provisions for clean energy projects wanting to claim the bonus tax credits for meeting prevailing wage and apprenticeship requirements, despite many requests by trade groups and other stakeholders to relax the documentation burden detailed in August's proposed regulations.
Research Credit Update
IRS Nixes Two Requirements for Research Credit Refund Claims - Erin Slowey, Bloomberg Tax($). "The IRS is waiving two requirements that taxpayers submit certain information with their research credit refund claim, the agency said Tuesday."
TCJA
Corporate Rate Revenue To Decrease After 2025, CBO Says - Asha Glover, Law360($):
The federal government will receive a projected $525 billion in corporate income taxes — 1.8% of GDP — in 2024 and $490 billion — 1.6% of GDP — in 2025, according to the CBO's update to its budget and economic outlook for 2024 to 2034. Corporate tax revenues are projected to continue to decline past 2025 after scheduled expirations and phase downs of the Tax Cuts and Jobs Act provisions, including one requiring scheduled payments for a one-time tax on corporate foreign profits that won't continue past 2026, the CBO said.
Blogs and bits
AbbVie Says IRS Can't Treat $1.6B Break Fee As Capital Loss - Kevin Pinner, Law360($). "The Internal Revenue Service cannot reclassify as a capital loss a $1.6 billion payment AbbVie made to an Irish biotechnology company after their failed merger and thereby raise the pharmaceutical giant's tax bill by $572 million, the company's attorneys told the U.S. Tax Court."
IRS Guidance Doesn't Perceive Spinoff Abuse, Official Says - Natalie Olivo, Law360($):
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The IRS in early May issued Notice 2024-38 alongside Revenue Procedure 2024-24, which reduces the range of spinoff plans that companies can bring to the agency for a private letter ruling stating that the transaction would be tax-free under Internal Revenue Code Section 355 . For example, the guidance suggests the agency will no longer give PLRs for reorganizations where a parent company wants flexibility when retaining some of its spun-off subsidiary's shares or intends to use them to pay off short-term debt.
Life Insurance Fraudster Deserves Tax Penalties, 7th Circ. Told - Kat Lucero, Law360($). "The IRS urged the Seventh Circuit to maintain nearly $400,000 in fraud penalties assessed against an Illinois man who pled guilty to falsifying his tax returns as part of a scheme to poison his wife and collect on a $20 million life insurance policy."
Former Tax Atty Hid Pension's $22.6M, Tax Court Says - Anna Scott Farrell, Law360($). "A former attorney who promoted himself as an expert in employee stock ownership plans failed to report nearly $22.6 million in income related to his acquisition of a furniture company's overfunded pension plan, the U.S. Tax Court ruled."
Happy National Ice Cream Soda Day! Root beer if my first choice, but Black Cows are a go-to at my house. Use your favorite ice cream soda treat to help you stay cool today!
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