Carina C. Federico

Featured in: Favicon

reuters.com Favicon

bloomberglaw.com Favicon

lexology.com Favicon

mondaq.com Favicon

bloombergtax.com Favicon

westlaw.com Favicon

lexblog.com Favicon

news.bloomberglaw.com Favicon

news.bloombergtax.com Favicon

today.westlaw.com

Articles

Transfer of Clean Energy Tax Credits

Aug 1, 2024 | reuters.com | Carina C. Federico

On April 25, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published final regulations to implement Section 6418 of the Code, a provision that allows a taxpayer to transfer to unrelated third parties the tax credits and related bonus credits for which certain clean energy projects may qualify (89 Fed. Reg. 34770 (Apr. 30, 2024)). Section 6418 of the Code was established under the Inflation Reduction Act (IRA) (Pub. L. 117-169, 136 Stat.
Crowell Talks Tax: IRA And Government Affairs Updates (Video)

Mar 4, 2024 | mondaq.com | Carina C. Federico |Tyler A. O'Connor

Tax partner Carina Federico is joined by Tyler O'Connor, an energy and government affairs partner, to discuss how the upcoming presidential election will affect the IRA.
Tax: Tax Credits Face Increased Enforcement Activity

Jan 12, 2024 | mondaq.com | Carina C. Federico

The IRS has been underfunded for many years, but that changed significantly with the landmark Inflation Reduction Act of 2022 (IRA), which gave the agency an additional $80 billion to be spent over 10 years. Unlike annual congressional allocations, this has allowed the IRS to make long-term investments and plans. It is clear the agency's strategy includes heightened scrutiny for various corporate tax credits.
IRS Commissioner Says the Employee Retention Credit Program “Will Go Forward.”

Nov 16, 2023 | lexology.com | S. Marshall |Carina C. Federico

What You Need to KnowKey takeaway #1Taxpayers with outstanding ERC claims will be pleased that the Commissioner has indicated that the IRS will restart its processing of ERC claims in the near future. Key takeaway #2Taxpayers who may have received funds to which they were not entitled may be encouraged by the IRS’s willingness to accept repayment of the funds over time.
IRS Announces Process to Withdraw Employee Retention Credit Claims

Oct 24, 2023 | lexology.com | Carina C. Federico |S. Marshall

This week, the IRS announced a new withdrawal process to allow certain employers who filed an Employee Retention Credit (ERC) claim, but have not yet received a refund, to withdraw their submission. As discussed in our previous alert, the IRS recently announced a pause in processing new ERC claims, at least through the end of 2023, due to concerns that many recently filed claims are invalid.
Proposed Rulemaking Issued on the CHIPS Act Advanced Manufacturing Investment Credit under IRC Section 48D

Mar 28, 2023 | lexology.com | Carina C. Federico |S. Marshall |Byron Brown |Samantha Skabelund

On March 23rd, the Treasury Department and the IRS published a notice of proposed rulemaking for the Section 48D Advanced Manufacturing Investment Credit (“Section 48D credit”) established by the CHIPS Act of 2022. Over the last few years, the market for semiconductors has been volatile, causing supply chain shortages.
Supreme Court Ruling Reduced Taxpayer’s Penalties by $2.67 Million

Mar 6, 2023 | lexology.com | S. Marshall |Carina C. Federico |Carlton Greene |Samantha Skabelund

In 2021, two Circuit Court of Appeals, held diametric positions regarding penalties for taxpayers who non-willfully failed to file a Report of Bank and Financial Accounts (FBAR): The Ninth Circuit concluded that the penalty was $10,000 per untimely filed FBAR, while the Fifth Circuit concluded that the penalty was $10,000 per account on each untimely filed FBAR.