More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more
The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more
6/27/2024
/ 16th Amendment ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Moore v US ,
Repatriation ,
SCOTUS ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Revenues
In Cotto-Vázquez v. United States, CIV. NO.: 16-2807 (SCC) (D.P.R. March 11, 2021), Miguel Ángel Cotto-Vázquez (Cotto),1 the former four-time Puerto Rican boxing champion, became involved in another fight. This time he faced...more
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
3/10/2021
/ Appeals ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Puerto Rico ,
Remand ,
Residency Requirements ,
Statute of Limitations ,
Tax Court ,
Tax Returns ,
Virgin Islands
Highlights -
• In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
7/15/2019
/ Controlled Foreign Corporations ,
Domestic Partnership ,
GILTI tax ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Minority Shareholders ,
New Guidance ,
New Regulations ,
Pass-Through Entities ,
Passive Foreign Investment Company ,
S-Corporation ,
Stocks ,
Subpart F ,
U.S. Treasury