News & Analysis as of August 24, 2025

Penalties

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

Freeman Law on 6/9/2025

As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Employers Are Obligated to Comply with Tax Law Despite Increase in Frivolous Tax Arguments

Littler on 5/20/2025

In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more

UK Reporting for Share Plans With UK Participants Due 6 July

Cooley LLP on 5/5/2025

The deadline is approaching for the HM Revenue & Customs (HMRC) year-end reporting requirements for companies in the UK, US and elsewhere with share options and other share awards granted to – and share acquisitions by – UK...more

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on 3/5/2025

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

Freeman Law on 2/10/2025

Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on 1/23/2025

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans - January 2025

Orrick, Herrington & Sutcliffe LLP on 1/23/2025

Annual Information Statements and IRS Returns Requirement to Report For (1) any exercise of an incentive stock option (ISO) during 2024 or (2) transfer during 2024 of a share previously purchased pursuant to a tax-qualified...more

Approaching Deadline: Reporting for ISO Exercises and ESPP Stock Transfers Due Beginning January 31, 2025

Kilpatrick on 1/20/2025

This alert is a reminder of the approaching deadlines for certain year-end reporting requirements applicable to corporations that issue stock to employees (including former employees) upon the exercise of certain stock...more

IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers - January 2025

Fenwick & West LLP on 1/20/2025

The IRS has issued two forms (along with accompanying instructions) that corporations must use to satisfy the return and information statement requirements under Section 6039 of the Internal Revenue Code of 1986, as amended....more

Deadline Approaching for Reporting 2024 ISO Exercises and ESPP Share Transfers

Goodwin on 1/17/2025

The Internal Revenue Code requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding exercises of incentive stock options (ISOs) by employees...more

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

Vinson & Elkins LLP on 1/14/2025

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Lessons from the Hunter Biden Tax Evasion Scandal

Fleurinord Law PLLC on 9/20/2024

Would you risk prison time to avoid paying taxes? That’s a question Robert Hunter Biden, publicly known as "Hunter Biden," may have asked himself when he faced serious tax evasion charges recently. While the case...more

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on 5/31/2024

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

Gray Reed on 10/11/2023

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more

Corporate Transparency Act Update—FinCEN Issues Final Rule

Keating Muething & Klekamp PLL on 10/6/2022

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued the highly anticipated final rule, Beneficial Ownership Information Reporting Requirements (the “Final Rule”), implementing the beneficial...more

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on 9/1/2022

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

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