Just over a year ago, the IRS––armed with Inflation Reduction Act (IRA) funding and resources––announced how the increased funding

            For those of us justifiably dissatisfied with this season of House of the Dragon, recent ERC action may lend some

With a flurry of IRS announcements regarding wealthy individuals and large partnerships, recent guidance on related-party basis transactions may have been easily overlooked. For many,

On June 18, 2024, the IRS modified the required information taxpayers must provide to the Service when submitting an I.R.C. § 41 research credit refund

On June 28, 2024, the Supreme Court issued its long-awaited opinion in Loper Bright Enterprises et al. v. Raimondo, Secretary of Commerce, et al., overturning

The IRS has finally come up for air to offer insight into its months-long “review period” of pending Employee Retention Credit (“ERC”) claims. On June

The Supreme Court released its eagerly awaited opinion in Moore v. United States yesterday. The majority opinion is carefully uncontroversial. The Court held that Congress

On May 2, 2024, the IRS released its 2024 update to its strategic operating plan highlighting the impact of the Inflation Reduction Act (“IRA”). In

In an important decision for assessable international penalties, last week the D.C. Circuit reversed a Tax Court decision holding that the IRS could not assess

On February 29, 2024, the Internal Revenue Service (“IRS”) announced a new effort targeting high-income non-filers who have failed to file federal income tax returns.