On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more
10/24/2023
/ Corporate Counsel ,
Corporate Taxes ,
Foreign Corporations ,
High Net-Worth ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Audits ,
Tax Incentives
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more
On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more
On July 6, 2023, the US Tax Court issued its decision in Betz v. Commissioner, T.C. Memo. 2023-84. Betz considers the application of the pilot model supply rule to expenses incurred by a designer (CPI) of made-to-order air...more
Over the years, case law has developed around when a mail delivery method is acceptable to prove that a tax filing was made.
The US Court of Appeals for the Fourth Circuit’s recent decision in Pond v. United States[1] ...more
The Internal Revenue Service (IRS) issued a news release reminding taxpayers to submit their 2019 income tax returns by July 17, 2023, to claim their refunds. Internal Revenue Code Section 6511 provides the period in which a...more
On June 2, 2023, US President Joe Biden announced that he has picked Marjorie Rollinson as the Internal Revenue Service (IRS) Chief Counsel, the top attorney position at the IRS. Rollinson has had a distinguished career in...more
The Internal Revenue Service (IRS) has invited suggestions on improving conference options at the Independent Office of Appeals (IRS Appeals) for taxpayers and representatives who are not located near an IRS Appeals office...more
The Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division updated its list of Active Campaigns, which includes more than 50 efforts to increase tax compliance. Each campaign identifies the practice...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more
The Internal Revenue Service (IRS) has proposed regulations to clarify the rules regarding supervisory approval of federal civil tax penalties under IRC Section 6751(b). Since Chai v. Commissioner, there has been a...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon...more
The US Senate has confirmed Daniel Werfel as the next commissioner of the Internal Revenue Service (IRS). The Senate voted 54-42, achieving bipartisan support for the nominee....more
In a surprising move, the Supreme Court of the United States (SCOTUS) dismissed a dispute involving the proper test to apply when determining whether an unnamed law firm’s mixed bag of communications involving both legal...more
On December 22, 2022, the Internal Revenue Service (IRS) finalized changes to Schedule UTP, Uncertain Tax Position Statement, and Instructions for Schedule UTP. Proposed changes to Schedule UTP and the UTP Instructions were...more
Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v....more
For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal Revenue Service (IRS) of adjustments...more
On November 21, 2022, the Supreme Court of the United States denied certiorari in Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9. This means that the US Court of Appeals for the...more
We frequently post about the Internal Revenue Service’s (IRS) tax enforcement trends and announcements. Prior examples from this year include the release of a five-year strategic plan emphasizing enforcement, the plan to hire...more
We previously discussed the Internal Revenue Service’s (IRS) announcement regarding draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Instructions to Schedule UTP (Form 1120). The IRS requested...more
On November 10, 2022, US President Joe Biden announced his intent to nominate Danny Werfel to serve as Commissioner of the Internal Revenue Service. US Secretary of the Treasury Janet Yellen has expressed her support for...more
The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share your tax information with foreign...more
On October 18, 2022, the Internal Revenue Service (IRS) announced the annual inflation adjustments for 2023 related to more than 60 tax provisions, with some increasing, some maintaining and some new additions to the list...more
US Congress will be giving the Internal Revenue Service (IRS) $79.6 billion over the next 10 years in an effort to put the agency back on the path to effective and efficient tax administration. The money will find lots of...more
On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more