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Fifth Amendment › Internal Revenue Code (IRC)

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

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The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Troutman Pepper Locke

IRS Finalizes New Rules for DeFi Brokers: Challenge Immediately Filed in Texas Federal Court

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The U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of...more

Katten Muchin Rosenman LLP

IRS Broker Rule for Digital Assets Faces Constitutional Challenge From Industry Leaders

Katten Muchin Rosenman LLP on

Three digital asset organizations have jointly filed a lawsuit challenging the Internal Revenue Service’s (IRS) new digital asset broker reporting rule. The complaint, filed in the Northern District of Texas on December 27,...more

Lippes Mathias LLP

Know Your Rights: Managing Exposure During Audits Through Legal Representation

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The 2022 Inflation Reduction Act (the “IRA”) allocated $80 billion in funding to the Internal Revenue Service (“IRS”), much of which was earmarked for increased enforcement efforts. After some starts and stops, that funding...more

Troutman Pepper Locke

Preparing for IRS Cash Transaction Reporting in the Cannabis Industry

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The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more

Freeman Law

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

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In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the Constitution’s...more

Freeman Law

Representing Taxpayers in Sensitive Audits: A Look at the Fundamental Challenges of an Eggshell Audit

Freeman Law on

Sensitive audits present the tax practitioner with unique challenges.  They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and...more

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