Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for summary judgement and found that contrary to the plain language of IRC § 7701(o), there is no prerequisite requirement that…
Continue Reading Tax Court to Revisit Problematic Economic Substance RulingCue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]
Summers are the ideal time for movies, baseball, long and winding road trips across the…
Continue Reading Cue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]The IRS has started its own Employee Retention Credit Olympics
Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again…
Continue Reading The IRS has started its own Employee Retention Credit OlympicsOn July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the…
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Last April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating…
Continue Reading What’s Next for International Reporting Post-Farhy?As Employee Retention Tax Credit (ERC) claims pile up and the IRS shows no signs of lifting its moratorium on processing claims filed after September 14, 2023, businesses with unpaid…
Continue Reading Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?The March 22 deadline for applying to the IRS Voluntary Disclosure Program (VDP) to repay improperly claimed Employee Retention Credits (ERC) at a discount is just around the corner. The…
Continue Reading March 22 ERC Voluntary Disclosure Deadline Rapidly ApproachingThe IRS is sending out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. The IRS will…
Continue Reading IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)
The IRS recently issued a news release identifying seven signs that a business’s Employee Retention Tax Credit (the “ERC”) may be incorrect. The IRS Commissioner also testified before the House…
Continue Reading IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)There are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.
They include an indefinite extension of the agency’s…
Continue Reading IRS and Congress Expand Efforts to Address ERC FraudNew IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount
The IRS has announced a new Voluntary Disclosure Program (VDP) offering businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits at a discount while avoiding penalties and interest.
Continue Reading New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a DiscountIRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program
In its most recent effort to fight fraudulent and improper Employee Retention Tax Credit (ERC) claims, on December 6, 2023, the IRS announced it will be notifying an initial group…
Continue Reading IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure ProgramThis post is authored by Nicholas Lyskin (foxrothschild.com), Kristy Caron (foxrothschild.com) and Brian C. Bernhardt (foxrothschild.com)
Most appraisers don’t go to prison, and those that do, don’t go for…
Continue Reading One Appraiser Goes to Prison, Another Goes Home: What to Expect from the IRSAbout this Blog
Published by attorneys in the White-Collar Criminal Defense & Regulatory Compliance and Taxation & Wealth Planning practices of national law firm Fox Rothschild LLP, Tax Controversy and Financial Crimes Report reports on the latest developments in all aspects of tax controversy and financial crimes.