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 ProgramAmid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims
The IRS recently announced that it will offer certain employers an opportunity to withdraw Employee Retention Credit (ERC) claims if they are concerned about their accuracy. Qualifying employers may be
Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims
IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism in Israel
In Notice 2023-71, the IRS provided tax relief for individuals affected by Hamas’ terroristic action in the State of Israel beginning on October 7, 2023. Notably, this relief is not
Continue Reading IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism 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
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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 collectivesTax 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
Increase in IRS Funding Leading to More Audits of Public Charities
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 CharitiesTenth Circuit: No Fifth Amendment Defense to the Application of Section 280E
I 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
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Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses
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
Section 280E Litigation Update: Harsh Results for Resellers
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