What is the Report of Foreign Bank and Financial Accounts (FBAR)?
Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
7/23/2021
/ Automatic Stay ,
Cryptocurrency ,
Enforcement ,
Income Taxes ,
IRS ,
Reasonable Compensation ,
State Taxes ,
Tax Benefits ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Webinars
In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more
7/22/2021
/ Bitcoin ,
Cryptocurrency ,
Ethereum ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
New Guidance ,
Section 1031 Exchange ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Virtual Currency
In a recent decision, a federal district court found that a long-time CPA/tax-return preparer recklessly failed to file FBARs to disclose several foreign financial accounts. As avid readers of our Insights are aware, many...more
What are the tax consequences of unwinding a transaction? And just when, if ever, is a taxpayer entitled to the transactional equivalent of a mulligan—a do-over? The ability to unwind a transaction depends upon the...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of July 5 – July 9, 2021 -
Peterfreund v. Commissioner,...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of June 21 – June 25, 2021 -
Ervin v. Commissioner, T.C....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of June 14 – June 18, 2021 -
Bell Capital Management, Inc....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
...more
The Week of April 26 – April 30, 2021 -
Plentywood Drug, Inc. | April 26, 2021 | Holmes| Dkt. No. 17753-16 -
Short Summary: The Tax Court was asked to decide whether rent paid by the Taxpayer was reasonable. The...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of May 3 – May 7, 2021 -
Chancellor v. Comm’r, T.C. Memo....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of February 22 – February 26, 2021 -
Llanos v. Commissioner...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of February 8 – February 12, 2021 -
BM Construction v....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of January 25 – January 29, 2021 -
Costello v. Comm’r, T.C....more
2/8/2021
/ Abuse of Discretion ,
Charitable Deductions ,
Farms ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Rental Income ,
Rental Property ,
Startups ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Liens ,
Tax Returns
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of January 18 – January 22, 2021 -
Adams Challenge (UK)...more
1/27/2021
/ Business Expenses ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
Investment Management ,
IRS ,
Management Fees ,
Shareholder Distributions ,
Tax Deductions ,
Tax Planning ,
Tax Returns ,
Tax Treaty
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
11/24/2020
/ C-Corporation ,
Corporate Taxes ,
Corporate Understatements ,
Deficiency Notices ,
Foreign Affiliates ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Returns ,
Transfer Pricing
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of October 31 – November 6, 2020 -
Glade Creek Partners,...more
11/12/2020
/ Charitable Deductions ,
Clerical Errors ,
Conservation Easements ,
De Novo Standard of Review ,
Income Taxes ,
IRS ,
Joint and Several Liability ,
Joint Tax Returns ,
Jurisdiction ,
Material Misstatements ,
Scope of Review ,
Spouses ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Underpayment
Jason B. Freeman and Matthew L. Roberts of Freeman Law, PLLC discuss the recent Second Circuit decision in Trump v. Vance. The case involves the ongoing battle between President Trump and the Manhattan District Attorney's...more
IRS debt can be a life-changing burden. But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start. When a taxpayer qualifies for an offer in compromise, the IRS...more
In the latest podcast episode, Jason B. Freeman of Freeman Law, PLLC and Eric Green of Tax Rep Network cover the recent New York Times article regarding President Trump's past taxes. The NYT coverage includes allegations that...more
As tax time approaches for many, taxpayers and tax professionals alike are engaging in the annual ritual of gathering their cryptocurrency transactions and seeking out the latest and greatest guidance from the IRS on the...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
10/8/2020
/ FBAR ,
Filing Requirements ,
Foreign Corporations ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Statute of Limitations ,
Tax Returns
Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance. That is, in part, what makes a recent report from the Treasury...more