Investors in U.S. businesses, particularly nonresident foreign investors and U.S. tax-exempt entities, often face unique tax considerations when structuring investments. One common planning tool used to manage these considerations is a “blocker” C corporation. A blocker C corporation can help…
For partnerships governed by the centralized partnership audit regime, a court’s final decision may feel like crossing the finish line, but for those electing to “push out” adjustments, the race isn’t quite over. The Bipartisan Budget Act of 2015 (“BBA”)[1]…
On June 18, 2024, the IRS modified the required information taxpayers must provide to the Service when submitting an I.R.C. § 41 research credit refund claim. The IRS had previously released a memorandum in October 2021 instituting five required pieces of information…
Background: Effects of Underfunding (2010–2021) On May 2, 2024, the IRS released its 2024 update to its strategic operating plan highlighting the impact of the Inflation Reduction Act (“IRA”). In the updated plan, the IRS notes that underfunding of the agency…
IRS Launches ERC Claim Withdrawal Process On October 19, 2023, the IRS alerted taxpayers of the Employee Retention Credit (“ERC”) withdrawal process. The IRS created the program to assist taxpayers who may have been solicited by ERC promoters into filing…
IRS Warns Taxpayers About Inflated Art Donation Deductions On October 5, 2023, the IRS issued a news release warning taxpayers to keep an eye out for promotions concerning inflated art donation deductions. Promoters of these schemes may solicit to taxpayers directly, typically…
IRS Implements Moratorium on New ERC Claims On September 14, 2023, IRS Commissioner Danny Werfel ordered an immediate moratorium running through at least December 31, 2023, on processing new Employee Retention Tax Credit (“ERC”) claims. The halt on processing new claims serves…
