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Breaking Up Is Not Always Hard To Do—Consider A Tax-Free Corporate Division

Disagreements happen.  In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders.  Or, there may be acrimony amongst the shareholders for other reasons, as can...more

IRS Continues Focus On Large Partnerships: 3 Items To Watch Out For

In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this program, the IRS identified...more

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

IRS Concedes Yet Another Form 3520 Related Penalty Case

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations...more

The IRS is Attacking Abusive Trust Arrangements

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims

For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims.  More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

Federal Courts Mixed on Whether the 90-Day Tax Court Petition Deadline Under Section 6213 is Jurisdictional

Deadlines are important, particularly in federal tax law.  Many taxpayers are aware, for example, of the significant penalties that the IRS may impose upon them for failure to timely file an income tax return or timely pay...more

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