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Grace Period: IRS provides penalty relief for certain taxpayers filing late returns for taxable years 2019 and 2020

USA - August 26 2022 The Internal Revenue Service (the IRS) has provided penalty relief in Notice 2022-36 for certain taxpayers from failure to file penalties and certain…

Mary E. Monahan, Hasnain Valika

Inflation Reduction Act targets carried interests

USA - July 30 2022 On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The…

Daniel R. McKeithen, Wes Sheumaker, Brian Tschosik

Three is the magic number of new Paycheck Protection Program guidance from the IRS

USA - November 29 2021 The IRS recently released a trio of Revenue Procedures—2021-48, 2021-49, and 2021-50—related to the Paycheck Protection Program (PPP), which has been…

Robert S. Chase II, Daniel G. Strickland

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

USA - May 26 2021 Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on…

Aaron M. Payne, Ellen McElroy, Mary Kate Nicholson, Michael D. Resnick

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC —The Anti-Injunction Act has its limits

USA - May 25 2021 On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge…

M. Kristan Rizzolo, Graham R. Green, Robert S. Chase II, Ellen McElroy, Mary E. Monahan, Sarah E. Paul, Bradley M. Seltzer, Daniel G. Strickland