News & Analysis as of October 12, 2024

Audits

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

Holland & Knight LLP on 9/19/2024

The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

Rivkin Radler LLP on 4/24/2024

Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

IRS sees flight risk with corporate jets

Eversheds Sutherland (US) LLP on 2/28/2024

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Extending the Statute of Limitations for Assessing Federal Tax

McDermott Will & Emery on 1/17/2022

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

IRS Continues to Audit and Litigate Against Cannabis Businesses

Holland & Knight LLP on 4/23/2021

As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code). Enacted in 1982 in response to a...more

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on 12/8/2020

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

TIGTA Tasks IRS with Enhanced Enforcement of Noncompliant Expatriates

Holland & Knight LLP on 11/23/2020

The U.S. Treasury Inspector General for Tax Administration (TIGTA) recently audited the Internal Revenue Service's (IRS) programs to ensure compliance by expatriates with the provisions under Sections 877 and 877A of the...more

Section 280E – Why Are We Still Having This Discussion?

Seyfarth Shaw LLP on 1/31/2020

If you are in the cannabis industry, you should already know Section 280E of the Internal Revenue Code. It consists of only one sentence...more

Bracewell Tax Report: February 2018 #2

Bracewell LLP on 3/1/2018

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on 12/13/2016

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

IRS Updates Guide to Auditing Nonqualified Deferred Compensation Plans

Bradley Arant Boult Cummings LLP on 7/20/2015

The Internal Revenue Service (IRS) recently updated its “Nonqualified Deferred Compensation Audit Techniques Guide.” The Guide provides a framework for the IRS to audit nonqualified deferred compensation (NQDC) plans. Since...more

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