The U.S. District Court for the District of Columbia held that IRS Notice 2025-42, which eliminated the Five Percent Safe Harbor method for establishing “beginning of construction” for wind and ...
The IRS issued a news release announcing a restructuring of its public-private partnership with Security Summit partners to strengthen protections and enhance information sharing across the tax system to combat ...
The IRS issued a news release announcing that 27 states have elected to participate in the Federal Scholarship Tax Credit (FSTC) program enacted under the One, Big, Beautiful Bill. The ...
The U.S. Tax Court held that cryptocurrency staking rewards are includible in gross income under I.R.C. §61 upon receipt, entering decision for the IRS. Taxpayer, a married couple, held tokens ...
The U.S. Court of Appeals for the Ninth Circuit affirmed the Tax Court’s determination of a tax deficiency, holding that res judicata did not bar the civil tax proceedings following ...
The IRS has issued a private letter ruling on I.R.C. §336 and Treas. Reg. §301.9100 granting S corporation Target a 75-day extension to file the section 336(e) election statement treating ...
The IRS has issued a private letter ruling on I.R.C. §509 and Treas. Regs. §§1.170A and 1.509 determining that a substantial cash grant from Foundation to taxpayer qualifies as an ...
The IRS has issued a private letter ruling on I.R.C. §4942 and Treas. Reg. §53.4942 approving a private foundation’s set-aside of funds for historic property restoration, treating the set-aside as ...
The IRS has issued a private letter ruling on I.R.C. §475 and Treas. Reg. §301.9100 denying a C corporation’s request for an extension of time to make a mark-to-market accounting ...
The IRS has issued a private letter ruling on I.R.C. §1400Z and Treas. Reg. §301.9100 granting extension of time to self-certify as a qualified opportunity fund (QOF) effective from the ...
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