The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more
A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more
In Actavis v. U.S., a case at the intersection of tax law and patent law, the Federal Circuit held that generic drug companies’ Hatch-Waxman litigation expenses are “ordinary and necessary business expenses” and can be...more
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more
President Trump’s executive order (EO) “Restoring Public Service Loan Forgiveness,” issued March 7, 2025, sets limits on student loan forgiveness under the Public Service Loan Forgiveness (PLSF) program. But the language used...more
March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more
On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more
The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more
Short Summary: The IRS filed a motion to dismiss for lack of jurisdiction a petition timely filed by taxpayers using the Tax Court’s online petition generator. Petitions filed using the Tax Court’s online petition generator...more
The United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more
In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more
Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more
For those keeping score at home, it’s currently two wins for the IRS in as many years, and nada/zilch/zero for the fund managers, at least when it comes to the limited partner exception for self-employment taxes (the “Limited...more
In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
On December 27, the U.S. Tax Court issued an opinion declining to revisit its holding from 13 months earlier that a partner’s formal status as a “limited partner” under state law does not determine whether the partner is...more
If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more
On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more
In this Part XIV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a narrow aspect of Subchapter S that is often ignored or forgotten. An S corporation is not always a mere extension of...more
Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more
On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more
Taxpayers had mixed success in two recent research credit cases in the United States Tax Court. In Smith v. Commissioner, the taxpayer was an architectural firm....more
Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more