On May 13, 2022, in Reserve Mechanical Corporation v. Commissioner,[1] the U.S. Court of Appeals for the Tenth Circuit affirmed a Tax Court decision that a micro-captive insurance company did not qualify for the exemption from income tax
In a rare change of position, on June 2, 2022, the district court granted the government’s motion in CIC Services, holding the IRS was not required to return the disclosure documents obtained under Notice 2016-66 to nonparty taxpayers and material
Tax Practice Shareholder Pallav Raghuvanshi is quoted in an April 29 Thomson Reuters Checkpoint article titled “The Long Read: Catching Up With Crypto.”
Taxpayers and material advisors with current disclosure requirements or who have paid penalties for failing to disclose reportable transactions may wish to consult with their tax advisors about their ongoing duty to disclose or the procedure for obtaining a refund
In a bipartisan effort to pass new legislation to extend and provide for increased reporting under the Qualified Opportunity Zone (QOZ) Program, on April 7, 2022, members of Congress introduced the Opportunity Zones Transparency, Extension, and Improvement Act (the Act).
The Fourth Circuit in Cook v. United States held that federal tax penalty assessments and the payments the debtor made were not voidable fraudulent transfers that generally allow debtors to recover certain pre-bankruptcy payments.
In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA). Notice 2016-66 prescribed disclosure requirements for taxpayers and material advisors involved
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On 16 February 2022, the Netherlands and Colombia signed a tax treaty for the elimination of double taxation and the prevention of tax evasion and avoidance. The Treaty prevents double taxation and contributes to the economic interests of both countries.
On March 3, 2022, the U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.1 the IRS must follow the Administrative Procedures Act (APA) when identifying “listed transactions” for purposes of applying the I.R.C.
Greenberg Traurig Shareholder James O. Lang was named a “Top 25 OZ Attorney 2021” by Opportunity Zone Magazine. James Lang’s practice is focused on tax incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, tax credits, and state and