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FASB ISSUES Accounting Standards Update 2024-04 DEBT – DEBT WITH CONVERSION AND OTHER OPTIONS (Subtopic 470-20) Induced Conversions of Convertible Debt Instruments - November 2024
The Board is issuing this Update to improve the relevance and consistency in application of the induced conversion guidance in Subtopic 470-20, Debt— Debt with Conversion and Other Options. When the terms of a convertible debt instrument are changed to induce conversion of the instrument, current generally accepted accounting principles (GAAP) provide guidance for determining whether the transaction should be accounted for as an induced ...
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The User Fee for Letter Ruling Requests Is Increased Again
At the beginning of each year the IRS releases a revenue procedure detailing how to go about requesting a private letter ruling, closing agreement or determination letter. This year’s revenue procedure is Rev. Proc. 2025-1, 2025-01 IRB 1 (December 30, 2024). The annual revenue procedure has gradually expanded and now takes up 117 pages in the Internal Revenue Bulletin. For someone not familiar with the process of seeking private letter ...
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When a Small Cooperative Prevails in Litigation With the IRS, It May Be Entitled To Recover Some of Its Costs
Under certain limited circumstances, a taxpayer that substantially prevails in a tax dispute with the IRS may be able to recover a portion of its administrative and legal expenses (including attorney’s fees). See, Section 7430 of the Internal Revenue Code. Taxpayers eligible for recovery include individuals whose net worth at the time the civil action was filed did not exceed $2 million. Relief is also available for unincorporated ...
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Proposed Regulations Update Guidance on Section 30C Alternative Fuel Vehicle Refueling Property Credit
Internal Revenue Code (“Code”) Section 30C provides a credit for certain costs of qualified alternative fuel vehicle refueling property placed in service within low-income communities or non-urban census tracts. On September 19, 2024, the Internal Revenue Service (“Service”) published a proposed rule to provide additional guidance for the credit. Section 30C was enacted as part of the Energy Policy Act of 2005, and ...
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Loper Bright – Supreme Court Decision – Implications on Tax Regulations
In the Spring 2024 column of TAXFAX, David Antoni, Christopher Hanna and Eric Krienert of Moss Adams authored Loper Bright Goes Up to Supreme Court and Implications for Federal Agency Regulations. The article provided an overview of Loper Bright Enterprises v. Raimondo, Case No. 22-451, certiorari granted (May 1, 2023), for which the Supreme Court heard oral arguments on January 17, 2024. The case set-up a challenge to overturn the Supreme ...
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