The National Taxpayer Advocate (NTA) has identified a serious IRS problem in calculating Collection Statute Expiration Dates or CSEDs. Generally, under IRC § 6502, the IRS has 10 years to collect a liability from the date of assessment. After this…
Continue Reading IRS Collection After the Statute of Limitations

Those moving to Puerto Rico to avail themselves of the tremendous tax benefits of Puerto Rico Act 22 (now Act 60) are all too familiar with the bona fide residency test. In preparation for an IRS residency audit, they know…
Continue Reading Moving to a Tax Friendly State (Not So Fast)

On May 28, 2021, the Treasury Department published its General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, or “Green Book”, which details the Biden Administration’s tax-related proposals, including those with respect to cryptocurrency. In it, it…
Continue Reading Biden’s Compliance Agenda Targets Cryptocurrency

If your Non-Profit Charter has been revoked by the IRS, you have several options for reinstatement depending upon how soon you engage the IRS to correct the problem. For non-profit organizations who seek reinstatement within 15 months of revocation, they…
Continue Reading How to Reinstate a Non-Profit with the IRS (with Retroactivity)

• IRS seeks $32 million for crypto tax enforcement. It seeks $32 million ($3 million on IT specialist compensation, $6 million on hardware and software and $23 million on contractual services) to enhance cryptocurrency-related enforcement efforts. The funding will enable the

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Continue Reading Current Regulatory Trends and Enforcement in Cryptocurrency

It is well settled that upon an order of restitution, based on a criminal tax loss to the government, the IRS can file restitution-based tax liens and collect the restitution in the same manner as if it were a civil…
Continue Reading Can the IRS Impose a Penalty after a Restitution-Based Assessment?

An important crypto tax case has emerged in the U.S. District Court in the Middle District of Tennessee, (Jarrett v. U.S.). In the Jarrett case, the taxpayers owned a certain cryptocurrency and engaged in staking activities, and the IRS then…
Continue Reading Are Crypto Staking Rewards Taxable – Maybe? Decision Pending