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 ...
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 ...
The IRS provides two sample notices that plan administrators may use: one for eligible rollover distributions from designated ...
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 ...
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”) ...
Section 6039 of the Internal Revenue Code (Code) requires a corporation to furnish a written statement to any employee or former employee who ...
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