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 2017IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)
The 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)IRS and Congress Expand Efforts to Address ERC Fraud
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