The IRS has for the second time in as many years included monetized installment sales on its annual “Dirty Dozen” tax schemes list. As we discussed in a prior post, the “Dirty Dozen” list alerts taxpayers and practitioners to...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure -
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
1/25/2023
/ Business Entities ,
Corporate Structures ,
Corporate Taxes ,
FBAR ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Parent Corporation ,
Tax Liability ,
Tax Planning ,
Tax Treaty
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition -
Introduction -
The IRS recently released two chief counsel...more
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split -
Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty -
The Eleventh Circuit’s decision in Kroner v. Commissioner,...more
12/14/2022
/ Enforcement Actions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
Can digital asset or cryptocurrency investors that were customers or account holders in a failed cryptocurrency business claim a deduction for their digital asset or cryptocurrency loss? So far this year there have been four...more
This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more