The OBBB made several modifications to the Opportunity Zone program. Established by the Tax Cuts and Jobs Act (the “TCJA”) in 2017, the Opportunity Zone program was intended to encourage investment in businesses located in...more
The sweeping tax package known as the One Big Beautiful Bill (OBBB), which passed on July 3 and was signed by President Donald Trump by July 4, brings notable changes for tax-exempt organizations, including new limits on...more
Taxpayers had mixed success in two recent research credit cases in the United States Tax Court.
In Smith v. Commissioner, the taxpayer was an architectural firm....more
The Gift and Estate Tax Exclusion is currently scheduled to be reduced by approximately 50% in about 13 months. Without action from Congress, on January 1, 2026, the Exclusion will go from almost $14 million to about $7...more
As described in our October 24 article “IRS Offers Forgiveness for Erroneous Employee Retention Credit Claims” the IRS has increased scrutiny on claims for the Employee Retention Credit (“ERC”). The IRS halted processing...more
The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...more
Key Takeaways -
..The Seventh Circuit torpedoed a taxpayer’s research tax credits for two watercrafts.
..The decision creates confusion about how a taxpayer should document research activities and arguably undermines...more