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The Code Section 4960 Excise Tax on Excess Executive Compensation – Part I: Tax on Excess Compensation and Potential Tax Mitigation Strategies

The Tax Cuts and Jobs Act (signed into law in late 2017) added Section 4960 to the Internal Revenue Code (“Code”). Code Section 4960 imposes an excise tax (currently 21 percent) on certain excess ...
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IRS roundup: October 7 – October 23, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025. October ...
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New IRS Guidance Regarding Code Section 45Q Credits - Revenue Ruling 2021-13

The Internal Revenue Service (IRS) issued new guidance regarding Section 45Q tax credits (Revenue Ruling 2021-13). The IRS guidance addresses the application of Section 45Q of the Internal Revenue ...
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IRS to Issue Regulations on Effect of Section 67(g) on Certain Deductions for Estates and Nongrantor Trusts

The U.S. Treasury Department and the IRS announced on Friday, July 13, 2018, that they intend to issue regulations on the impact of new section 67(g) of the Internal Revenue Code of 1986 on certain ...
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IRS appears to walk back disregard of certain accounting method changes in proposed section 965 regulations–does it make a difference?

On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the ...
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IRS Issues Final Section 162(m) Regulations On Companies’ Ability To Deduct Executive Pay

The Internal Revenue Service (IRS) recently published final regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to Section 162(m) of the Internal Revenue Code (Section ...
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IRS Guidance Regarding the Section 4960 Excise Tax Is (Somewhat) Helpful

IRS Notice 2019-09 provides guidance intended to help “applicable tax-exempt employers” determine whether compensation paid to their most highly compensated employees will be subject to the 21 percent ...
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IRS Leans “Green”: Much-Awaited Section 45V Guidance Creates New Opportunities for Hydrogen Markets

On December 22, 2023, the Internal Revenue Service (IRS) published long-awaited proposed regulations for hydrogen tax credits under Internal Revenue Code (Code) Sections 45V and 48. The proposed ...
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IRS creates a standardized Section 83(b) Election form

On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620, 1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” ...
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IRS Updates Guidance on Section 530 and Worker Status Issues

IRS Revenue Ruling 2025-3 addresses employment classification disputes for employment tax purposes in five different factual situations. This ruling is specifically concerned with Section 530 of the ...
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Internal Revenue Code Section 162(m): Proposed Regulations

On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the ...
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A New Form Section 83(b) Election: IRS Form 15620

As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) ...