The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news
Continue Reading IRS Going All in on Use of ArtificiaI Intelligence
It is a truism that agencies required to publicly release documents sometimes hold off on releasing those documents until a Friday afternoon, in the hopes it will be overlooked. The
Continue Reading IRS is coming for NIL collectivesLast 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 RulingSummers are the ideal time for movies, baseball, long and winding road trips across the U.S. in search of the perfect family vacation or, just as important, a reasonable crypto
Continue Reading Cue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again stating that it will deny tens of thousands of ERC claims that, according to the
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 U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner
Continue Reading Partnership Interest Sale Inventory Gain is Not U.S. Source IncomeLast 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 2017The 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 Fraud