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
Continue Reading Tax Court to Revisit Problematic Economic Substance RulingWhat’s Next for International Reporting Post-Farhy?
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?
California FTB Unveils Microcaptive and Conservation Easement Settlement Initiative
The California FTB recently released a settlement initiative for taxpayers involved in microcaptive or syndicated conservation easement transactions. Taxpayers who enter into the settlement program will not be able to
Continue Reading California FTB Unveils Microcaptive and Conservation Easement Settlement InitiativeTax Court Rules IRS Cannot Assess Certain International Reporting Penalties
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties