Samantha Skabelund

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.

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.