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"2022 The Year in Review – Tax Law"

December 2022

Renesha Fountain provides the Tax Law update in the Texas Bar Journal’s 2022 The Year in Review December Issue

Renesha Fountain, senior counsel at Chamberlain Hrdlicka, has contributed the Tax Law Update for the “2022: Year in Review” December issue of Texas Bar Journal. In the article, she focuses on the tax impacts of the Inflation Reduction Act of 2022; the additional relief for taxpayers still recovering from the COVID-19 pandemic, announced by the IRS; and a favorable opinion for a taxpayer in a US Supreme Court case involving a request for a collection due process (CDP) hearing.

Discussing the tax impacts of the Inflation Reduction Act, Fountain reviewed the 15% alternative minimum tax imposed on publicly traded corporations that will apply to tax years beginning after December 31, 2022; the non-deductible excise tax of 1% of the fair market value of corporate stock repurchases taking effect after December 31, 2022; as well as the extension of the excess business loss limitation under I.R.C. § 461(l) for noncorporate taxpayers through tax years beginning before January 1, 2029. Taxpayers may also be eligible for several tax credits that were extended or expanded under the act.

Fountain also stated that “the act increased IRS funding by approximately $79.6 billion over the next ten years, the majority of which was allocated to enforcement actions and operations support.” The increased funding will allow the IRS to hire more personnel, modernize technology as well as increase tax compliance and taxpayer services.

Fountain maintains an active practice in tax planning and tax controversy and represents clients in disputes with the IRS and state and local taxing authorities. For the full article, go to https://tinyurl.com/5n7uk8mb.