Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes. Specifically, on August 9, 2023, IRS Chief Counsel issued a Memorandum on
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The IRS is Attacking Abusive Trust Arrangements
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes. Specifically, on August 9, 2023, IRS Chief Counsel issued a Memorandum on
When Taxpayer and IRS Can’t Agree, the Tax Court Must Intervene
On remand for re-calculation of 4 errors in deficiency amounts, concerning years 2003, 2004, 2005, and 2006, the Tax Court entered final revised decisions based on the Commissioner’s twice-revised Rule 155 computations.
During the Larkins’ appeal, the Commissioner acknowledged four
Joshua Smeltzer Quoted by Law360 on Treasury’s Proposed Digital Asset Reporting Rules Against Foreign Trading Platforms
The U.S. Treasury Department faces a complex task in enforcing its proposed digital asset reporting rules on foreign trading platforms. The regulations, introduced in late August, primarily address domestic transactions, leaving potential difficulties in enforcing reporting requirements on foreign digital
Is Your Partnership Ready for IRS Audit Initiatives? Because the IRS is Coming!
On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special passthrough organization to help audit initiatives for
Joshua Smeltzer Quoted by TaxNotes on Proposed IRS Penalty Approval Guidelines
The tax community is currently embroiled in a heated debate over proposed IRS guidelines concerning timing provisions, the broad scope of individuals eligible to approve penalties and exemptions related to automated penalty calculations.
At the heart of the controversy lies
Joshua Smeltzer Quoted by TaxNotes on Proposed IRS Penalty Approval Guidelines
The tax community is currently embroiled in a heated debate over proposed IRS guidelines concerning timing provisions, the broad scope of individuals eligible to approve penalties and exemptions related to automated penalty calculations.
At the heart of the controversy lies
IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC claims from September
IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC claims from September
IRS Announces New Compliance Efforts Aimed at High-Income Taxpayers, Partnerships, Digital Assets, FBARs and Labor Brokers
On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers. According to the announcement, the IRS has finalized its “top-to-bottom review” of current enforcement efforts and intends