After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
4/18/2023
/ Enforcement Actions ,
Federal Taxes ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Pass-Through Entities ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
3/14/2023
/ Bittner v United States ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
SCOTUS ,
Tax Liability ,
Tax Penalties ,
Tax Returns
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
1/12/2023
/ Charitable Donations ,
Conservation Easements ,
Federal Budget ,
Internal Revenue Code (IRC) ,
IRS ,
Pass-Through Entities ,
Regulatory Reform ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more