Joshua D Odintz

IRS Proposes to Classify Basket Contracts as a Tax Avoidance Scheme

The U.S. Department of the Treasury and IRS on July 11, 2024, issued proposed regulations that would classify certain basket contract transactions as listed transactions.

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

The IRS recently announced a new enforcement campaign that targets and investigates sports industry partnerships reporting significant tax losses.

Biden Administration's Made in America Tax Plan: Procedural Aspects

Part 1: Buckle Up for the Impact on International Tax Reform

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

Part 2: Buckle Up for the Impact on International Tax Reform

Biden's American Families Plan Proposes Income Tax Hikes

The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and the extension of tax cuts for families with children and American workers.

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap1 in the U.S. may total $1 trillion per year.

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important victory to CIC and similarly situated taxpayers everywhere.

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government.

Biden Administration's FY 2022 Budget and International Tax Changes

A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy," June 3, 2021.)

Agreement on Global Tax Reform: What Happened and What's Next

Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20 Inclusive Framework (IF)1 since 2015.

U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status

The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty).1

The Most Interesting International Tax Proposals in Biden's FY 2023 Budget

This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage before the Organization of Economic Cooperation and Development (OECD)...

The Inflation Reduction Act: Summary of the Budget Reconciliation Act

President Joe Biden signed the Inflation Reduction Act of 2022 (IRA) into law on Aug. 16, 2022, following its passage along party lines in the U.S. Senate and House of Representatives.

Notice 2023-7: First Peek at Corporate AMT Guidance

As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA).

Eyes on Energy Tax Update: January 2023

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments.

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code).

Treasury Department Releases Section 48C Guidance with Billions in Tax Credits Up for Grabs

Reinstated by the Inflation Reduction Act of 2022 (IRA), Section 48C of the Internal Revenue Code provides $10 billion in credits for qualifying advanced energy projects, $4 billion of which must be allocated to projects located in energy communities.1

Treasury Department, IRS Release Preliminary Low-Income Community Bonus Credit Guidance

Section 48 of the Internal Revenue Code provides an investment tax credit (ITC) for certain renewable projects, including solar and wind power projects, equal to 30 percent of the qualified investment in the project if prevailing wage and apprenticeship requirements are satisfied.

Treasury Department Issues Section 48D Guidance on CHIPS Act Semiconductor Tax Incentive

The U.S. Department of the Treasury and Internal Revenue Service recently released proposed regulations under Section 48D, providing helpful clarifications.

IRS Energy Community Bonus Guidance Provides Welcome Clarity

The Internal Revenue Service (IRS) released guidance regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E.

Treasury Department, IRS Release Clean Vehicle Tax Guidance

Treasury Department, IRS Release Clean Vehicle Tax Guidance

Eyes on Energy Tax Update: First Quarter 2023

Eyes on Energy Tax Update is a regular publication of the Holland & Knight Energy Tax Team that provides highlights of important energy tax developments.

The New IRS Selectivity Criteria for Advance Price Agreements and Renewals

The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests.

Break Out Your Calculator: IRS Releases Domestic Content Bonus Credit Guidance

Following the release of energy community bonus credit and low-income community bonus credit guidance, the U.S. Department of the Treasury and IRS recently provided taxpayers with the domestic content bonus credit guidance.

IRS and Department of Energy Release Additional Section 48C Guidance

Reinstated by the Inflation Reduction Act of 2022 (IRA), Section 48C of the Internal Revenue Code provides $10 billion in allocable credits for qualifying advanced energy projects, $4 billion of which must be allocated to projects located in energy communities.

Treasury Department, IRS Release Low-Income Community Bonus Credit Proposed Rules

The U.S. Department of the Treasury and IRS on May 31, 2023, released a Notice of Proposed Rulemaking (NPRM) regarding the low-income community bonus credit under Section 48 of the Internal Revenue Code. The NPRM requests comments by June 30, 2023.

Treasury Department and IRS Release Direct Pay and Transferability Guidance

As part of the Inflation Reduction Act, certain taxpayers may elect for a direct payment in lieu of a tax credit.

IRS Issues Updated Energy Community Bonus Guidance

The IRS on June 15, 2023, updated its energy community bonus guidance by issuing Notice 2023-45 and Notice 2023-47. The IRS also recently issued energy community bonus guidance in Notice 2023-29.

IRS Releases 2023 Section 45 Production Tax Credit Amounts

The IRS on June 21, 2023, released 2023 production tax credit (PTC) amounts under Section 45 of the Internal Revenue Code.

Inflation Reduction Act: Answers to Key Questions on Direct Pay and Transferability

In this alert, the Holland & Knight Energy Tax Team answers many of the key questions on direct payment and transferability of tax credits as provided for under the IRA.