For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more
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 tax reporting form. In response to the IRS’s...more
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 IRS at least “show clear signs of being erroneous,”...more
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 on the sale of her interest in a U.S....more
7/29/2024
/ Capital Gains ,
Foreign Partner ,
Income Taxes ,
Inventory Property Sales ,
IRS ,
Non-Resident Aliens ,
Partnership Interests ,
Partnerships ,
Promissory Notes ,
Tax Court ,
Tax Cuts and Jobs Act
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’ if...more
Businesses that reasonably anticipate that loans under the Paycheck Protection Program will be forgiven should be aware that they cannot claim a deduction for the eligible expenses paid or incurred during the 2020 taxable...more
11/23/2020
/ CARES Act ,
Consumer Utility Costs ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Deductions ,
Federal Loans ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Payroll Deductions ,
Rent ,
SBA ,
Small Business
The IRS intends to issue proposed regulations to permit a partnership or an S corporation to deduct specified income tax payments made to a domestic state or local jurisdiction.
In Notice 2020-75, the IRS clarifies that...more
Employers should weigh carefully whether to participate in the voluntary deferring of the employee portion of Social Security taxes pursuant to the executive memorandum issued by President Trump on August 8, 2020.
The...more
“Nothing can be said to be certain, except death and taxes.” ? Benjamin Franklin.
This familiar phrase resonates for daily fantasy sports (DFS) operators following the release of a July 23, 2020 Internal Revenue Service...more