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Conservation Easement Extinguishment Proceeds Regulation Found Invalid

Conservation Easement Extinguishment Proceeds Regulation Found Invalid D.F. Hewitt, CA-11, 2022-1 ustc¶50,102 The IRS’s interpretation of Reg. §1.170A-14(g)(6)(ii), which disallows the subtraction of post-donation improvements to property on which a conservation easement exists in the event of a judicial extinguishment, was arbitrary and capricious because it violated the procedural requirements of the Administrative Procedures Act (APA). As a […]

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Low-Income Housing Credit Deadlines Extended

Low-Income Housing Credit Deadlines Extended Notice 2022-5 The IRS extended several deadlines related to the low-income housing credit, in response to the continuing coronavirus (COVID-19) pandemic and precautions necessitated by new disease variants. The extensions generally apply to deadlines that occur between April 1, 2020, and December 31, 2022, for the: 10-percent test for carryover […]

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Final Regulations Address Foreign Tax Credit Issues

Final Regulations Address Foreign Tax Credit Issues The Treasury and IRS have issued final regulations affecting taxpayers that claim credits or deductions for foreign income taxes or claim a deduction for foreign derived intangible income (FDII). The regulations finalize 2020 proposed regulations (REG-101657-20) and address: the disallowance of a foreign tax credit or deduction for […]

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ABA Section Calls For Research Credit Refund Claim Regs

ABA Section Calls For Research Credit Refund Claim Regs The American Bar Association’s Section of Taxation is asking the Internal Revenue Service to issue regulations related to the filing of a research credit refund claim. In a January 6 letter to the agency, the Section suggested that an October 15, 2021, memorandum providing specific instructions […]

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Pandemic Highlights IRS’ Underfunding Issues

Pandemic Highlights IRS’ Underfunding Issues Two recent reports, one from the Internal Revenue Service and the other from the National Taxpayer Advocate, show how the ongoing pandemic exposed the effects of being an underfunded agency. The IRS in its recently issued Progress Update report for fiscal year 2021, highlights some of those issues caused by the pandemic […]

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