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IRS Clarifies Coordination of Section 174 Method Changes and Accelerated Recovery Elections

The IRS recently issued Revenue Procedure 2026-32, providing welcome clarification for taxpayers that improperly deducted domestic research and experimental (R&E) expenditures in tax years 2022 through 2024 and are now seeking to align with the capitalization requirements enacted under the Tax Cuts and Jobs Act. The guidance confirms that taxpayers may, in the same 2025…

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Data center servers with cityscape view. Financial graph and dashboard interface over blur city.
Beyond the Moratorium: A Policy Framework for Data Center Development in New York

Artificial intelligence is driving unprecedented demand for data center capacity, prompting states across the country to reconsider how these facilities are taxed, regulated, and integrated into existing infrastructure. As policymakers weigh the economic benefits of AI-driven investment against growing concerns over electricity demand, grid reliability, water consumption, and public costs, the focus is shifting from…

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ai infrastructure in a data center.
The $1 Trillion Question: New York’s Data Center Moratorium and the Future of AI Infrastructure

Data centers have become critical infrastructure for the modern economy. Artificial intelligence models, cloud platforms, financial systems, healthcare applications, defense technologies, cybersecurity platforms and communications networks all rely on physical computing infrastructure capable of storing and processing vast volumes of information. According to the Electric Power Research Institute (EPRI), data centers currently consume approximately 4%…

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Bowen v. Commissioner Narrows the Scope of Landmark COVID-Era Tax Relief

The Tax Court’s recent decision in Bowen v. Commissioner provides new guidance on the scope of potential Covid-era refund claims arising from Kwong v. United States. To understand the ramifications of Bowen for taxpayers who are potentially eligible for refunds under Kwong, it is helpful to begin with what the Kwong case established. What Kwong Established The…

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Series FF stock is a special class of equity typically issued to founders at the time of incorporation.
What Is Series FF Stock? A Founder-Friendly Alternative to Redemption Rights

Founders often face a difficult balancing act: providing investors with downside protection while maintaining flexibility for future growth. Traditional redemption rights can protect investors, but they may also create cash flow burdens and unintended tax consequences. Series FF stock offers an alternative approach that can help align founder and investor interests while preserving important tax…

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TAX BENEFITS. Concept of business, finance and tax. Time to pay tax in year. Planning budget.
Illinois AIM Tax Credit Rewards Investment, Not Just New Factories

Every so often, a state incentive comes along that is worth rearranging a capital plan, and Illinois may have one in its Advancing Innovative Manufacturing (AIM) Tax Credit. AIM offers Illinois income tax credits of up to 7% of qualified capital improvement investment to manufacturers and research-driven businesses that build, modernize, or relocate operations in…

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