On Feb. 28, 2024, the Florida Legislature passed Senate Bill (SB) 328, the Live Local Act “glitch bill,” amending and clarifying 2023’s Live Local Act affordable housing law,[1] and the bill is on its way to Gov. DeSantis’ desk for signature. If signed into law, SB 328 would, among other changes, make three
On Feb. 29, the Internal Revenue Service announced a new initiative targeting individuals who failed to file income tax returns for 2017 and later years. This initiative, funded by the Inflation Reduction Act, follows on the agency’s larger effort to examine large corporate, partnership, and high-income individual filers. See September 2023 GT Alert. It
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On Feb. 14, 2024, the California Office of Tax Appeals (OTA) denied the Franchise Tax Board (FTB)’s petition for rehearing, confirming its opinion in Appeal of Microsoft Corporation. The decision allows Microsoft to include 100% of its foreign dividends in the sales factor denominator.
The issuance of a partnership profits interest is a tax-efficient tool for a partnership (including an LLC or other entity treated as a partnership for tax purposes) to incentivize its employees or other service providers. If structured properly, the grant of a profits interest should not constitute a taxable event for the recipient. In addition,
Following the impact of remote and hybrid work on San Francisco, the San Francisco Offices of Treasury and Controller drafted a joint proposal to mitigate risks in the current tax structure. The proposal may serve as a framework for a ballot measure presented to voters on the November 2024 ballot. The proposal currently is revenue
On Feb. 16, the IRS Office of Chief Counsel released a legal memorandum concluding that third-party payers, such as professional employer organizations (PEOs), certified professional organizations, and Section 3504 Agents (collectively, “TPPs”) are liable for underpayments of payroll taxes resulting from improper claims for the employee retention credit (ERC) that the TPPs filed on behalf
On Jan. 16, 2024, the Senate Finance Committee and House Ways and Means Committee chairs announced their bipartisan agreement to a tax package that would include several new tax provisions (including an expansion of the childcare tax credit, an extension of 100% bonus depreciation, and several others). However, to offset the costs of these provisions
The Internal Revenue Service (IRS) opened the portal for taxpayers to register for elective payment (under Section 6417 of the Internal Revenue Code (Code)) or transfer (under Section 6418 of the Code) for the ITC, PTC, and other eligible federal income tax credits. Along with the registration portal, the IRS provided a user guide and
The Internal Revenue Service (IRS) and U.S. Department of the Treasury (Treasury) issued proposed regulations, published in the Federal Register Dec. 26, 2023, applicable to clean hydrogen production facilities.
Notably, the proposed regulations address:
On Dec. 21, 2023, the Internal Revenue Service (IRS) announced a new voluntary disclosure program (VDP) for taxpayers who have received an employee retention credit (ERC) refund for which they might not have been eligible. Eligible taxpayers wishing to participate in the VDP must apply by March 22, 2024.
