The IRS released a draft of a new tax form, Form 1099-DA, that brokers will use to report proceeds from certain digital asset transactions. The draft Form 1099-DA can be found on the IRS website and below. The effective date...more
Effective as of January 1, 2023, payors of qualified plan distributions have been required to use a redesigned IRS Form W-4P for payee withholding elections on periodic payments and a new Form W-4R for nonperiodic payments...more
On April 3, 2023, the Tax Court ruled in Farhy v. Commissioner1 that the Internal Revenue Service (IRS) lacks the authority to assess penalties under Section 6038(b) of the Internal Revenue Code (the Code) and may not proceed...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 27, 2022 – March 5, 2022... March 1, 2022: The IRS issued final regulations increasing...more
On November 22, 2021, the Internal Revenue Service (IRS) published proposed regulations that codify, among other things, an automatic extension of the deadline for furnishing IRS Forms 1095-C to employees. IRS Forms 1095-C...more
The substance over form doctrine (and related step transaction and economic substance doctrines) are often invoked by courts to disallow tax consequences that seem too good to be true. Courts have struggled for years with how...more
In 2014 the IRS issued Notice 2014-21 (“Notice”) regarding the application of the Internal Revenue Code to transactions using virtual currency. The IRS advised that virtual currencies which could be “customarily used and...more