Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
District Court Holds Tax Liens Stay with Property after Conveyance
United States v. Gerard, a recent case from the Northern District of Indiana, demonstrates how a tax lien, once attached, can stay with property even after the property is
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Law Firm Shareholders Liable for Trust Fund Recovery Penalties
The Internal Revenue Code requires employers to withhold certain taxes in “a special fund in trust for the United States” (sec. 7501(a)). IRS regulations require employers to pay these trust
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New Tax Bill Means Changes for Employers: What You Need To Know
Our colleague Tiana R. Seymore has authored a client alert addressing several provisions in the Tax Cuts and Jobs Act which directly impact the workplace, including one that gives some
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Changes to Estate and Gift Taxes in the New Tax Law
Our colleague Debra T. Hirsch has authored a client alert addressing estate and gift tax planning issues impacted by the Tax Cuts and Jobs Act, which took effect yesterday. You
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IRS Issues Guidance Regarding Deductibility of Prepaid Real Property Taxes
The Internal Revenue Service advised tax professionals and taxpayers today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances.
The IRS
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The Tax Cuts and Jobs Act’s Impact on Domestic M&A Transactions
Our colleagues Stanley Barsky, Michael S. Bookbinder, and Eric J. Michaels have published an article about several provisions in the Tax Cuts and Jobs Act — signed into
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Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized
We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to
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An Overview of the Proposed Tax Reform Bill
On Thursday, November 2, the House Ways and Means Committee released the proposed Tax Cuts and Jobs Act, which proposes significant revisions to the Internal Revenue Code. According to
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Facts on Tax: The Executive Summary on Corporate Tax Reform
On October 16, 2017, the White House released the Council of Economic Advisers’ Report, entitled Corporate Tax Reform and Wages: Theory and Evidence. The Report comes in the wake
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