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.
The IRS announced on February 21 that it will start an audit campaign investigating potential personal use of business aircraft. The campaign will begin with
As of January 1, 2024, the Financial Crimes Enforcement Network (“FinCEN”) is now accepting Beneficial Ownership Information Reports. Under the Corporate Transparency Act, certain domestic
On October 19, 2023, the IRS alerted taxpayers of the Employee Retention Credit (“ERC”) withdrawal process. The IRS created the program to assist taxpayers who
In an October 20, 2023, announcement, the IRS set out a trio of initiatives aimed at corporate taxpayers. The initiatives are part of an effort
On October 5, 2023, the IRS issued a news release warning taxpayers to keep an eye out for promotions concerning inflated art donation deductions. Promoters
On September 20, 2023, the IRS created a new workgroup to substantially expand enforcement efforts related to pass-through organizations not subject to corporate income tax,
On September 14, 2023, IRS Commissioner Danny Werfel ordered an immediate moratorium running through at least December 31, 2023, on processing new Employee Retention Tax
Congratulations! You’ve reached a basis for settlement with the Appeals Officer. In previous articles, we’ve provided pointers on the Protest, Preparation, Presentation, and Persistence. The
You are in the middle of your initial conference with the Appeals Officer. So far, you’ve been able to keep to your well-prepared script. Your
Several months have passed since your first contact with the Appeals Officer. You’ve had several calls with her. She’s read your well-written protest. (It’s well-written
It’s been about six months since you’ve submitted your Protest to your examination manager. You’ve heard nothing from the examiner – no rebuttal, nothing. Then,
Your client manufactures heavy farm equipment. It has a network of independently owned dealerships that employ sales staff to sell the equipment to customers. From
133 Peachtree Street, NE
Suite 4900
Atlanta, Georgia 30303
Tel. (404) 382 – 9942
Fax (404) 565 – 1103
