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 collectivesIn 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
As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff
Continue Reading Increase in IRS Funding Leading to More Audits of Public CharitiesI have written before about the battles being fought by cannabis businesses facing IRS examinations. IRS audits raise many issues for state legal cannabis businesses operating in violation of the
Continue Reading Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E
Yesterday the Tax Court issued two decisions discussing the impact of Section 280E on cannabis businesses. One of these cases addresses the application of Section 280E to licensed and non-licensed
Continue Reading Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses
In the latest Tax Court opinion addressing the application of Section 280E to cannabis businesses there is no good news. However, there is some new guidance. In Patients Mutual Assistance
Continue Reading Section 280E Litigation Update: Harsh Results for Resellers
The IRS recently reminded taxpayers that like-kind exchanges are now generally only available for exchanges of real property. This change was enacted as part of the Tax Cuts and Jobs
Continue Reading Like-kind Exchanges Limited to Real Property
New Jersey recently announced the New Jersey Tax Amnesty program. The New Jersey Division of Taxation has indicated that both individuals and businesses may qualify for the program. The amnesty
Continue Reading New Jersey Offers Tax Amnesty Program
The Bipartisan Budget Act of 2018 eases the requirements for combat-zone contractors to claim the foreign earned income exclusion. A U.S. citizen is generally taxed on his worldwide income. The
Continue Reading New Law Eases Requirements for Combat-Zone Contractors to Claim Foreign Earned Income Exclusion