IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Going All in on Use of ArtificiaI Intelligence
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
IRS is coming for NIL collectives
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 collectivesFBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
Introduction
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines
Continue Reading FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit SplitTax Court to Revisit Problematic Economic Substance Ruling
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 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 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]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 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 OlympicsPartnership Interest Sale Inventory Gain is Not U.S. Source Income
On 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 IncomeWhat’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?
Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?
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?
March 22 ERC Voluntary Disclosure Deadline Rapidly Approaching
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 ApproachingIRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017
The 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 2017