The Coronavirus Disease 2019 (COVID-19) crisis has raised questions and concerns about upcoming property tax payment and reporting deadlines in California and whether taxpayers may be entitled to any relief due to a decline in property values. The discussion below addresses these issues. April 10 Property Tax Payment Deadline California state legislators, the state controller, the California Association of County Treasurers and Tax Collectors, and various county tax collectors have recently issued statements regarding the…

Frequently Asked Questions (FAQs) posted by the IRS provide additional information regarding the tax return filing and tax payment deadline relief announced by the IRS in Notice 2020-18. The IRS indicated that the FAQs will be continue to be updated. Key information in the FAQs: The filing extension until July 15 only applies to those income tax returns due April 15. The relief does not apply to those returns that were due March 16; Section…

On March 20, 2020, the IRS issued Notice 2020-18, extending the April 15, 2020, due date for filing federal income tax returns and making federal income tax payments to July 15, 2020, for all affected taxpayers. IRS Notice 2020-18 supersedes IRS Notice 2020-17, which was issued two days earlier, on March 18, 2020, and provided for a capped amount of federal income tax payments to be deferred until July 15, 2020. The new…

The IRS has released Notice 2020-15 stating that if a high deductible health plan covers COVID-19 testing and treatment even though the deductible has not been met, the coverage for testing and treatment will not disqualify the insured’s tax deductible contributions to a Health Saving Account (HSA). In order to be eligible to make tax-deductible contributions to an HSA, the individual can only be covered by a high deductible health plan. IRS Notice 2020-15 provides…

On Feb. 19, 2020, the IRS released Notice 2020-12 and Revenue Procedure 2020-12 (together, the “Carbon Guidance”) which provide highly anticipated clarity on the Internal Revenue Code Section 45Q credit for carbon oxide sequestration. The Carbon Guidance provides details on determining when construction has begun on an eligible project, and valid partnership allocations (including a permissible partnership flip structure), which in each case are very similar rules to those applicable or relied upon in solar…

In a unanimous decision written by Justice Neil Gorsuch (Rodriquez v. FDIC No 18-12690), the Supreme Court vacated a decision by the U.S. Court of Appeals for the Tenth Circuit (In re United Western Bancorp, Inc., 914 F. 3d 1262 (10th Cir, 2019)) that awarded a federal income tax refund of a failed bank to the Federal Deposit Insurance Corporation as receiver. The award was opposed by the Chapter 7 bankruptcy trustee for the holding…

On Feb. 19, 2020, the Internal Revenue Service released partial guidance on the implementation of section 45Q tax credits related to the capture and sequestration of carbon dioxide. The section 45Q tax credit was updated on Feb. 9, 2018, as part of the Bipartisan Budget Act (Pub. L. 115-123) to increase the amount of the tax credit per ton and to broaden the applicability to include “qualified carbon oxide.” The new IRS guidance is…