The Internal Revenue Service (IRS) recently announced a new settlement initiative for Syndicated Conservation Easements (SCEs) that are currently under audit and have not reached the Tax Court. This new settlement initiative...more
Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
4/18/2023
/ Enforcement Actions ,
Federal Taxes ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Pass-Through Entities ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
3/14/2023
/ Bittner v United States ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
SCOTUS ,
Tax Liability ,
Tax Penalties ,
Tax Returns
The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more
The IRS just announced, in releasing Notice 22-36, that it will be automatically issuing an estimated $1.2 billion in refunds or credits related to failure to file penalties assessed against taxpayers on a broad range of 2019...more
On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (H.R. 5376) (the “Act”). The announced goal of the Act is to create an economic initiative to address various climate protection initiatives. In...more
8/12/2022
/ Biden Administration ,
Corporate Taxes ,
Excise Tax ,
Federal Funding ,
Internal Revenue Code (IRC) ,
IRS ,
Pending Legislation ,
Regulatory Agenda ,
Tax Credits ,
Tax Deductions ,
Tax Reform