With the IRS ERC moratorium still in effect, employers are carefully considering their options including litigation. Recently, the IRS indicated it was prioritizing low-risk claims while flagging others as problematic. With no clear end in sight for the moratorium, some
In the upcoming months, the U.S. Treasury and the IRS will be defending regulations aimed at curbing what they deem abusive tax practices, such as the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax
Gray Reed Partners Austin Carlson and Joshua Smeltzer will be speaking in a webinar hosted by the CalCPA. CalCPA is the largest state CPA society in the nation, representing and supporting certified public accountants and related professionals in California.
Scheduled
On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth
The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them reportable transactions. A “listed transaction” is a transaction that is
Gray Reed has recently filed two significant amicus briefs challenging the Securities and Exchange Commission’s (SEC) controversial “regulation by enforcement” approach, particularly in emerging technology sectors.
The first brief was filed on behalf of the Texas Blockchain Council and the
Co-author Lee Bratcher, Founder and President of the Texas Blockchain Council
Cryptocurrency has grown from a niche digital curiosity to a mainstream financial instrument. With the surge in popularity and the increase in transactions involving cryptocurrencies, the IRS has intensified
On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the constitutionality and
Married taxpayers can file their taxes together or separately. Because it is often more tax-advantageous and convenient to file together, most married individuals elect to file as married filing jointly. But there are risks with this approach. When spouses file
New rules proposed by the U.S. Treasury Department relax disclosure requirements for certain offshore retirement accounts but leave classification questions unresolved. The guidance raises the reporting threshold for overseas retirement trusts, exempting more accounts than the 2020 procedure. However, uncertainty
