Get Revenue Ruling 1998 - 21 - Transfer Of ... - Uncle Fed's Tax *Board

Section 6418 of the Internal Revenue Code (the Code) allows certain taxpayers to elect to transfer all (or any portion specified in the election) of an eligible credit to an unrelated transferee taxpayer; the transferee taxpayer then is able to utilize the transferred tax credit (or such portion thereof) against its ...

Section 6418(a) states that an eligible taxpayer can elect to transfer all (or any portion specified in the election) of an eligible credit determined with respect to such eligible taxpayer.

For tax years beginning after December 31, 2022, an eligible taxpayer may elect to transfer all or a specified portion of eligible credits to an unrelated transferee (IRC § 6418). Eligible credits are several energy-related components of the general business credit and the investment tax credit (IRC § 6418(f)(1)).

The Act encourages the IRS to adopt a liberal acceptance policy for taxpayer offers-in-compromise and installment agreements. The Act generally prohibits the IRS from levying on a taxpayer.

For the first time, pursuant to Section 6418, taxpayers are allowed to transfer all (or any portion) of an eligible credit to an unrelated taxpayer for cash consideration. Generally, the follow tax credits may be eligible for transfer: Energy Credit (Section 48) Clean Electricity Investment Credit (Section 48E)

Federal Vacancies Reform Act of 1998 - Revises provisions regarding the filling of Federal vacancies to authorize the President, if an appointed officer of an executive agency (defined to include the Executive Office of the President and exclude the General Accounting Office (GAO)) dies, resigns, or is otherwise unable ...

In brief. The Inflation Reduction Act of 2022 enacted Section 6417, providing for direct payment of some energy tax credits, and Section 6418, allowing taxpayers to transfer certain energy credits. Sections 6417 and 6418 apply to tax years beginning after 2022.

Section 1203 of the Internal Revenue Service Restructuring and Reform Act of 1998 (the “RRA”) provides generally that IRS employees must be terminated from Federal employment if they violate certain rules in connection with the performance of their official duties.