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IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

by , and | Oct 24, 2023 | ,

On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to the IRS thanks to the Inflation Reduction Act of 2022 (IRA). (We previously reported on how IRS enforcement is impacted by IRA funding here.) The announcement explains:

The IRS is working to ensure large corporate and high-income individual filers pay the taxes they owe. Prior to the Inflation Reduction Act, more than a decade of budget cuts prevented the IRS from keeping pace with the increasingly complicated set of tools that the wealthiest taxpayers use to hide their income and evade paying their share. The IRS is now taking swift and aggressive action to close this gap.

The announcement also outlines three new initiatives aimed at collecting tax revenue from large corporations:

1. The large foreign-owned corporations transfer pricing initiative. The IRS will focus its attention on US subsidiaries of foreign companies that distribute goods in the United States. Based on data likely received through the now retired Inbound Distributor Campaign, the IRS believes that some of these foreign companies “report losses or exceedingly low margins year after year through the improper use of transfer pricing to avoid reporting an appropriate amount of U.S. profits.” To jump start its initiative, the IRS will be notifying 150 subsidiaries of large foreign corporations “to reiterate their U.S. tax obligations and incentivize self-correction.” These “soft letters” can be a prelude to an audit.

2. The IRS will expand its Large Corporate Compliance (LCC) program. We previously reported on the LCC program, which focuses on noncompliance by using data analytics to identify large corporate taxpayers for audit. With an increased number of staff as a result of IRA funding, the IRS will commence examination of an additional 60 corporations that were selected using a combination of artificial intelligence and subject matter expertise. Key selection metrics will include factors from the various active compliance campaigns.

3. Cracking down on the abuse of former Internal Revenue Code (IRC) Section 199 domestic production activity deduction. The IRS has been battling taxpayers’ IRC Section 199 deductions since its promulgation. We have reported extensively on this topic over the years. The battle between the IRS and taxpayers has heated up in the wake of the repeal of IRC Section 199, which precipitated taxpayers filing billions of dollars of refund claims. The recent $1.8 billion taxpayer loss in Bats Global Market Holdings, Inc., No. 22-9002 (10th Cir. July 12, 2023), aff’g 158 T.C. No. 5 (2022), has clearly emboldened the IRS to intensify its existing Section 199 audit campaign to address noncompliance and review high-risk claims.

In the announcement, the IRS also reported that it has been pursuing high income, high-wealth individuals who have either not filed their taxes or failed to pay recognized tax debt. The IRS is focused on taxpayers with more [...]

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It’s Official: President Biden Signs the Inflation Reduction Act into Law, IRS to Receive Increased Funding

by and | Aug 17, 2022 | , ,

On August 16, 2022, US President Joe Biden signed into law the Inflation Reduction Act of 2022 (Act). A press release from the White House touts the Act as one that will “lower the costs for families, combat the climate crisis, reduce the deficit, and finally ask for the largest corporations to pay their fair share.” The press release provides a numerical summary of the Act’s impact on the healthcare, clean energy and tax sectors.

As we previously discussed, the Act provides for a significant increase in funding for the Internal Revenue Service (IRS). IRS Commissioner Chuck Rettig shared the following written statement regarding the Act:

The signing of the historic reconciliation package marks a transformational moment for our agency—and an opportunity for the future of tax administration. The IRS has struggled for many years with insufficient resources to fulfill our important mission. During the next 10 years, these funds will help us in many areas, including adding critical resources to not just close the tax gap but meaningfully improve taxpayer service and technology. This will allow the IRS to provide services to taxpayers in the manner they expect and deserve. The act also includes a wide range of tax law changes that we will have to implement very quickly.

 

Given the scope of the bill, keep in mind these changes will not be immediate. It’s a 10-year plan, and it will take time to put these provisions into place. More details will be available in coming months.

 

We have a lot of hard work in front of us to deliver on the high expectations this historic funding will provide. But I have great confidence IRS employees are up to the task—and will deliver for Americans as they have countless times before in the history of our agency.

The Act also contains several new provisions relating to the corporate alternative minimum, a tax on stock buybacks, and tax credits for clean energy use and production. These provisions will require immediate guidance given that they are effective for taxable years beginning after December 31, 2022.

Practice Point: The IRS has its work cut out for it. It is critical that timely guidance be provided to taxpayers impacted by the Act’s new provisions to allow for proper planning and modeling. Additionally, the IRS needs to create and execute a plan to improve its technology and customer service.

Update as of August 18, 2022: US Secretary of the Treasury Janet Yellen has issued a memorandum to Commissioner Rettig, directing the IRS to produce, within six months, an operational plan detailing how the additional funding would be deployed over the next decade. Secretary Yellen specifically stated that she would like the IRS to work closely with Deputy Secretary of the Treasury Wally Adeyemo “to identify specific operational initiatives and associated timelines that will improve taxpayer service, modernize technology, and increase equity in our system of tax administration [...]

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Weekly IRS Roundup April 15 – April 19, 2024

by , and | Apr 22, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15, 2024 – April 19, 2024.

April 15, 2024: The IRS released Internal Revenue Bulletin 2024-16, which includes the following:

  • Announcement 2024-16, which describes the experience, structure and activities of the Advance Pricing and Mutual Agreement Program during calendar year 2023.
  • Proposed regulations, which would revise regulations pertaining to the advance notice provided to taxpayers before the IRS contacts third parties. These proposed regulations are intended to conform to the new statutory language of Section 7602(c) of the Internal Revenue Code (Code), enacted as part of the Taxpayer First Act of 2019, and provide exceptions to the 45-day advance notice requirement where delaying contact with third parties for 45 days after providing notice to the taxpayer would impair tax administration.
  • Announcement 2024-17, which contains corrections to proposed regulations under Code Sections 761 and 6417 that address certain electricity production credits.
  • Notice 2024-30, which expands the Nameplate Capacity Attribution Rule under Section 4.02(1)(b) of Notice 2023-29 to include additional attribution property. The notice also adds two 2017 North American Industry Classification System industry codes to the table in Section 3.03(2) of Notice 2023-29, which are relevant for purposes of determining the Fossil Fuel Employment rate (as defined in Section 3.03(2) of Notice 2023-29).
  • Notice 2024-32, which addresses the eligibility of loan borrowers through State Supplemental Loan programs and the loan size limitation for State Supplemental Loans. The notice also provides guidance on whether an issue of state or local bonds, the proceeds of which are used to finance or refinance qualified student loans or to finance qualified mortgage loans, is a refunding issue.
  • Proposed regulations, which would identify certain charitable remainder annuity trust transactions and substantially similar transactions as listed transactions. Material advisors and certain participants in these listed transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
  • Revenue Procedure 2024-19, which provides the process under Code Section 48(e) to apply for an allocation of environmental justice solar and wind capacity limitation as part of the low-income communities bonus credit program for 2024. The revenue procedure also describes how the capacity limitation for the 2024 program year will be divided across the facility categories described in Sections 48(e)(2)(A)(iii) and 1.48(e)-1(b)(2), the Category 1 sub-reservation described in Section 1.48(e)-1(i)(1) and the additional selection criteria application options described in Section 1.48(e)-1(h).
  • Revenue Ruling 2024-8, which provides the terminal charge and Standard Industry Faire Level mileage rates used for valuing noncommercial flights on employer-provided aircraft.

April 15, 2024: The IRS announced it has answered over one million more taxpayer phone calls this tax season, helped over 170,000 more people in person and saw 75 million more IRS.gov visits [...]

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Weekly IRS Roundup April 8 – April 12, 2024

by , and | Apr 15, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024.

April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15, which includes the following:

  • Announcement 2024-15, which revokes the § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under § 170(b)(1)(A) of the Internal Revenue Code (Code).
  • Notice 2024-31, which provides adjustments to the limitation on housing expenses for purposes of Code Section 911 for specific locations for 2024.
  • Revenue Procedure 2024-17, which provides a waiver under Code Section 911(d)(4) concerning time requirements for individuals who must leave a foreign country because of war, civil unrest or similar adverse conditions and are electing to exclude their foreign earned income. The revenue procedure also adds Ukraine, Belarus, Sudan, Haiti, Niger and Iraq to the list of waiver countries for tax year 2023 for which the minimum time requirements are waived.
  • Revenue Procedure 2024-18, which supplements Revenue Procedure 2023-32 by publishing amounts of unused housing credit carryovers allocated to qualified states under Code Section 42(h)(3)(D) for calendar year 2023 (in addition to those amounts published in Revenue Procedure 2023-32).
  • Final regulations, which describe rules for the elective payment of Inflation Reduction Act of 2022 tax credit amounts in a taxable year, including definitions and special rules applicable to partnerships and S corporations and regarding repayment of excessive payments. The regulations also describe rules related to a required IRS pre-filing registration process.
  • Final regulations, which describe rules for the elective payment of the advanced manufacturing investment credit under the Creating Helpful Incentives to Produce Semiconductors Act of 2022, including special rules applicable to partnerships and S corporations, repayment of excessive payments, and basis reduction and recapture. The regulations also describe rules related to a required IRS pre-filing registration process.

April 8, 2024: The IRS warned taxpayers about bad tax information on social media that can potentially lead to identity theft and tax problems.

April 9, 2024: The IRS warned tax professionals and businesses to remain vigilant and protect themselves against a continuing barrage of email spearfishing attempts, especially one particular type known as “new client” scams where identity thieves pose as potential clients using fake emails in hopes of stealing valuable information.

April 9, 2024: The IRS reminded taxpayers that its Direct File pilot is open to eligible taxpayers in 12 pilot states and allows the filing of 2023 federal tax returns online for free and directly with the IRS.

April 9, 2024: The IRS released proposed regulations that would implement the statutory netting rule, which reduces the aggregate fair market value of stock repurchased by a taxpayer during a certain taxable year. Additionally, [...]

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Weekly IRS Roundup April 1 – April 5, 2024

by , and | Apr 11, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1, 2024 – April 5, 2024.

April 1, 2024: The IRS released Internal Revenue Bulletin 2024-14, which includes the following:

  • Notice 2024-29, which provides updates on the corporate bond monthly yield curve, the corresponding spot segment rates for February 2024 used under § 417(e)(3)(D) of the Internal Revenue Code (Code), the 24-month average segment rates applicable for March 2024, and the 30-year Treasury rates as reflected by the application of § 430(h)(2)(C)(iv).
  • Revenue Ruling 2024-7, which provides the April 2024 applicable federal rates.
  • Proposed regulations, which provide guidance on the Section 45V production tax credit added by the Inflation Reduction Act of 2022 (IRA) and on the election to treat qualified property that is part of a specified clean hydrogen production facility as energy property under Section 48.

April 1, 2024: The IRS warned taxpayers to beware of scammers attempting to sell or offer help setting up an online account on IRS.gov. Their goal is to get personal tax and financial information that can be used to commit identity theft.

April 2, 2024: The IRS reminded taxpayers there is still time to file federal income tax returns electronically and request direct deposit before the April 15 deadline.

April 2, 2024: The IRS warned taxpayers to beware of promotors who push improper Fuel Tax Credit claims by misleading taxpayers as it relates to fuel use and creating fictitious documents or receipts for fuel.

April 2, 2024: The IRS reminded taxpayers that the credit for other dependents is a $500 nonrefundable credit available to those with dependents who are not eligible for the Child Tax Credit. Taxpayers can claim this credit in addition to the child and dependent care credit and the Earned Income Credit.

April 3, 2024: The IRS reminded taxpayers affected by the terrorist attacks in Israel that they have until October 7, 2024, to file various federal individual and business tax returns that were originally due March 15 or April 15, make tax payments and perform other time-sensitive tax-related actions.

April 3, 2024: The IRS warned taxpayers to avoid offer in compromise (OIC) “mills” that aggressively mislead by raising false expectations and exploiting vulnerable individuals with promises that tax debt can magically disappear. OIC mills are on the IRS’s “Dirty Dozen” list.

April 3, 2024: The IRS reminded taxpayers who adopted or started the adoption process in 2023 that they may qualify for the adoption credit.

April 4, 2024: The IRS warned taxpayers about groups masquerading as charitable organizations to attract donations from unsuspecting contributors and gather sensitive personal and financial information that can be exploited for tax-related identity fraud.

April 4, 2024: The IRS
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Weekly IRS Roundup February 26 – March 1, 2024

by , and | Mar 6, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 26, 2024 – March 1, 2024.

February 26, 2024: The IRS released Internal Revenue Bulletin 2024-9, which includes the following:

  • Announcement 2024-11, which shares recent disciplinary sanctions involving lawyers, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents and appraisers.
  • Revenue Procedure 2024-12, which extends the time for providing certain seller reports for vehicle sales that qualify for the clean vehicle credit or the previously owned clean vehicle credit under Internal Revenue Code (Code) §§ 30D and 25E, respectfully.
  • Revenue Procedure 2024-13, which provides two tables of limitations on depreciation deductions for owners of passenger automobiles placed in service during calendar year 2024 and a table of dollar amounts that must be used to determine income inclusions by passenger automobile lessees with a lease term beginning in calendar year 2024.
  • Revenue Procedure 2024-14, which provides indexing adjustments for applicable dollar amounts under Code § 4980H(c)(1) and (b)(1). These indexed amounts are used to calculate the employer shared responsibility payments under § 4980H(a) and (b)(1), respectively.

February 26, 2024: The IRS announced that it will accept supplemental applications from all qualified organizations for Low Income Taxpayer Clinic matching grants from February 26 to April 10.

February 26, 2024: The IRS provided businesses, tax professionals and others who want to learn more about resolving incorrect Employee Retention Credit (ERC) claims a free webinar about the ERC Voluntary Disclosure Program and other IRS efforts to help taxpayers who may have been misled by aggressive marketing and misinformation around ERC eligibility.

February 27, 2024: The IRS announced that individuals and businesses in parts of California affected by severe storms and flooding that began on January 21, 2024, now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments.

February 27, 2024: The IRS announced that two private sector experts with extensive experience in the tax and cryptocurrency industries have been hired as executive advisors to help the agency’s efforts within the digital assets space.

February 27, 2024: The IRS released Notice 2024-26, which provides that withholding agents (both US and foreign persons) are administratively exempt from the requirements to electronically file Forms 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, that are required to be filed in calendar year 2024. Additionally, withholding agents that are foreign persons are administratively exempt from the requirements to electronically file Forms 1042 that are required to be filed in calendar year 2025.

February 28, 2024: The IRS reminded taxpayers that recent improvements to Where’s My Refund? provide more information and remains the best way to check the status of a refund, including information regarding IRS confirmation [...]

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IRS Announces New Audit Initiative Focused on Jet Airplane Usage

by and | Mar 1, 2024 |

On February 21, 2024, the Internal Revenue Service (IRS) announced a new initiative to audit the use of airplanes by corporations, large partnerships and high-net-worth individuals. While the IRS has always examined plane usage, this new focus aligns with recent IRS messaging that corporations and high-income taxpayers are not paying their “fair share” of tax and have been subject to “historically low audit rates.” The IRS will use some of its Inflation Reduction Act of 2022 funding to step up its enforcement efforts in this area.

Indeed, the IRS has been keeping score and publicly sharing their successes in collecting tax from millionaire taxpayers. We have also previously reported on the IRS’s strengthened enforcement plans thanks to its newfound funding.

The IRS’s airplane usage audit initiative will focus on allocations between business and personal use, which highlights several potential tax issues, including:

  • Limitations on deductions per Internal Revenue Code Section 274
  • Limitations on deprecation and recapture under Internal Revenue Code Section 280F
  • Whether the value of a flight is income to the passenger and/or guests (See Reg. §1.61-21).

Practice Point: If you have an airplane and claimed tax deductions for its use and ownership, you should prepare for an IRS examination. What can you do now? First and foremost, you should maintain meticulous records that fully substantiate the business use of the plane. For example, adding more detail about what the plane was used for, how it was used, and tying its use to a business purpose will be key to winning over an IRS auditor. Second, make sure the maintenance and flight log records are up to date and correct. Also, although not directly related to the recently announced IRS’s audit initiative, do not forget to ensure compliance with Federal Aviation Administration regulations and sales tax, use tax, and federal excise tax considerations, particularly if you decide to reorganize the ownership or organizational structure of an entity that owns an aircraft.



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Weekly IRS Roundup January 15 – January 19, 2024

by , and | Jan 23, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024.

January 16, 2024: The IRS released Internal Revenue Bulletin 2024-3, which includes the following:

  • Notice 2024-10, which provides guidance on the corporate alternative minimum tax, including rules for determining the “adjusted financial statement income” of a US shareholder when a controlled foreign corporation pays a dividend and modifications to Notice 2023-64.
  • Proposed regulations, which provide guidance on the new Internal Revenue Code (Code) Section 45X advanced manufacturing production credit established by the Inflation Reduction Act of 2022 (IRA). This credit is intended to incentivize domestic production of certain green energy components.
  • Final regulations regarding penalty protections for de minimis errors on information returns and payee statements.

January 16, 2024: The IRS released transitional guidance under Code Section 60501 on reporting transactions involving the receipt of digital assets and clarified that at this time, digital assets are not required to be included when determining whether cash received in a single transaction (or two or more related transactions) meets the reporting threshold.

January 16, 2024: The IRS issued Revenue Ruling 2024-3, which provides the February 2024 applicable federal rates.

January 16, 2024: The IRS reminded taxpayers of their rights under the Taxpayer Bill of Rights, which includes 10 rights all taxpayers have any time they interact with the IRS. Those rights include privacy, confidentiality and the right to appeal an IRS decision in an independent forum.

January 17, 2024: The IRS announced the appointment of 12 new members to the Internal Revenue Service Advisory Council, a public forum that provides the IRS and agency leaders with feedback, observations and recommendations related to tax administration.

January 18, 2024: The IRS reached a major milestone in the implementation of key provisions in the IRA as more than 1,000 projects have now been registered through the new IRS Energy Credits Online tool.

January 18, 2024: The IRS alerted a limited group of tax-exempt organizations subject to unrelated business income tax that they will not be able to electronically file Form 990-T, Exempt Organization Business Income Tax Return, or Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations, until March 17, 2024.

January 19, 2024: The IRS issued Notice 2024-20, which provides guidance on the qualified alternative fuel vehicle refueling property credit under Code Section 30C. The IRS intends to issue additional guidance via proposed regulations.

January 19, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).



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Weekly IRS Roundup January 8 – January 12, 2024

by , and | Jan 16, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 8, 2024 – January 12, 2024.

January 8, 2024: The IRS released Internal Revenue Bulletin 2024-2, which includes the following:

  • Notice 2024-7, which provides eligible taxpayers with automatic relief from additions to tax for failure to pay with respect to certain income tax returns for 2020 and 2021.
  • Announcement 2024-3, which explains Voluntary Disclosure Program eligibility criteria, terms and procedures for taxpayers to resolve refunds or credits for erroneous Employee Retention Credit (ERC) claims.
  • Notice 2024-2, which provides guidance on certain SECURE 2.0 Act of 2022 provisions.
  • Notice 2024-3, which sets forth the 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans.
  • Notice 2024-4, which updates the corporate bond monthly yield curve and corresponding spot segment rates for December 2023 used under Internal Revenue Code (Code) § 417(e)(3)(D), the 24-month average segment rates for December 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
  • Revenue Ruling 2024-1, which provides covered compensation tables under § 401(1)(5)(E) for the 2024 plan year.
  • Notice 2024-1, which provides the percentage increase for calculating the qualifying payment amounts for items and services furnished in 2024 for purposes of Code §§ 9816 and 9817, §§ 716 and 717 of the Employee Retirement Income Security Act of 1974, and §§ 2799A-1 and 2799A-2 of the Public Health Service Act.
  • Notice 2024-6, which provides additional guidance on the sustainable aviation fuel (SAF) credit, including methods and Renewable Fuel Standard program safe harbors used to qualify for and calculate the SAF credit.
  • Announcement 2024-1, which revokes § 501(c)(3) determinations for certain organizations and stipulates that contributions made to the organizations by individual donors are no longer deductible under § 170(b)(1)(A).
  • Notice 2024-5, which provides a safe harbor for the incremental cost of certain qualified commercial clean vehicles placed in service in calendar year 2024 for purposes of the credit pursuant to § 45W.
  • Notice 2024-8, which provides the optional 2024 standard mileage rates that taxpayers can use when computing the deductible costs of operating an automobile for business, charitable, medical or moving expense purposes.
  • Notice 2024-9, which notes the IRS’s intent to propose regulations concerning statutorily required exceptions to the elective payment phaseout for entities that do not satisfy the domestic content requirements of §§ 45, 45Y, 48 and 48E. The notice also provides the transitional process for how applicable entities can claim the statutory exception for elective payment projects that begin construction during calendar year 2024 and fail to satisfy the domestic content requirement.
  • Notice 2024-11, which updates the list of treaties that meet the requirements of § 1(h)(11)(C)(i)(II) as it relates to [...]

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Weekly IRS Roundup November 27 – December 1, 2023

by | Dec 7, 2023 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 27, 2023 – December 1, 2023.

November 27, 2023: The IRS released Internal Revenue Bulletin 2023-48, which includes Revenue Procedure 2023-34 and sets forth the annual inflation adjustments for various Internal Revenue Code provisions for tax year 2024. Also included are the tax rate schedules and other tax changes.

November 27, 2023: The IRS and Security Summit partners launched the eighth National Tax Security Awareness Week along with tips for taxpayers and tax professionals to avoid scams and protect sensitive personal information ahead of the upcoming 2024 filing season and throughout the year.

November 27, 2023: The IRS published Tax Tip 2023-124, which reminds taxpayers that the IRS has newsletters for a variety of tax topics and audiences.

November 27, 2023: The IRS published proposed regulations that would amend the rules applicable to plans that include cash or deferred arrangements under § 401(k) to provide guidance for long-term, part-time employees. Comments and requests for a public hearing must be received by January 26, 2024.

November 27, 2023: The IRS published proposed regulations that would update current regulations regarding whether certain persons are treated as related persons who are subject to certain special rules pertaining to transactions with partnerships. The proposed regulations would affect partnerships that enter into transactions with related persons that result in a gain or loss on a sale or exchange of property or result in a difference in the timing recognition of income and deductions on account of the persons’ different methods of accounting. Comments and requests for a public hearing must be received by February 26, 2024.

November 28, 2023: The IRS reminded tax professionals to protect themselves and their clients’ sensitive information, including by putting written security plans in place and by following new requirements to use multifactor authentication.

November 28, 2023: The IRS highlighted its continued support of international efforts to fight fraud and charity scams in light of Charity Fraud Awareness Week.

November 28, 2023: The IRS published Tax Tip 2023-125, which reminds paid tax return preparers to renew their Preparer Tax Identification Number via the online renewal process before it expires on December 31, 2023.

November 29, 2023: The IRS reminded taxpayers that they can get extra protection against identity theft during the 2024 tax season by joining the Identity Protection Personal Identification Number program.

November 30, 2023: The IRS urged businesses to remain vigilant against cyberattacks aimed at stealing their customers’ personal information and other business data.

December 1, 2023: The US Department of the Treasury and the IRS issued two guidances on the § 30D clean vehicle credit excluded entity restriction, as amended by the Inflation Reduction Act [...]

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