News & Analysis as of

Internal Revenue Code (IRC) Income Taxes Tax Audits

Foster Garvey PC

Hobby Loss Rules Revisited

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With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Ankura

The Critical Importance of Tax Due Diligence in Modern Business Transactions

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In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more

Farrell Fritz, P.C.

IRS Releases Strategic Operating Plan Update Outlining Future Priorities

Farrell Fritz, P.C. on

The Internal Revenue Service (“IRS”) released an update to its plan to transform agency work and improve taxpayer experience. The update to the Strategic Operating Plan provides “an outline of the major projects and outcomes...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Plans To Increase Audits of Personal Use of Business Aircraft

On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more

McDermott Will & Emery

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

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On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more

Freeman Law

Tax Court in Brief | Patacsil v. Comm’r | Insolvency to Avoid Recognition of Cancellation-of-Indebtedness income; Net Operating...

Freeman Law on

Summary: Ernesto Patacsil and Marilyn Patacsil (“Taxpayers”) owned a business that ran group homes for consumers with intellectual or physical maladies in California, being an expensive yet statutorily encouraged...more

Vinson & Elkins LLP

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

Vinson & Elkins LLP on

The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more

Freeman Law

Is Your Trade Associations prepared for IRS audit? IRS Issues Technical Guidance for 501(c)(6) Organizations

Freeman Law on

On September 16, 2022, the IRS published its Exempt Organizations Technical Guide TG 6 IRC 501(c)(6) Business League (“TG6”). TG6 discusses tax exemption of business leagues, chambers of commerce, real estate boards, and...more

Foodman CPAs & Advisors

How does the IRS enforce the Nation’s Tax Laws for the benefit of all Taxpayers?

On December 17, 2020, the IRS published a document entitled “Closer Look”. It explains the IRS aspiration for balancing the Taxpayer burden with the potential benefit of its compliance effort when deciding which compliance...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

McDermott Will & Emery

Weekly IRS Roundup August 12 – 16, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12 – 16, 2019. August 12, 2019: The IRS issued a news release announcing that John...more

Foodman CPAs & Advisors

Taxpayers can be Embarrassed when IRS Contacts a Third-Party

Under Internal Revenue Code (IRC), Subtitle F - Income Taxes, Chapter 78 - Discovery of Liability and Enforcement of Title, Subchapter A - Examination and Inspection – Section 7602, the IRS has the authority to contact a...more

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

Holland & Knight LLP on

• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

Holland & Knight LLP

Six Tips for Tribal Governments to Reduce Tribal Member Taxes in 2018

Holland & Knight LLP on

• President Donald Trump on Dec. 22, 2017, signed the Tax Cuts and Jobs Act, the first major overhaul of the U.S. tax system in over 30 years. • Although few of the enacted provisions are specific to Indian Country, several...more

Burr & Forman

Federal Employment Taxes: Employee-Independent Contractor Issues (Part 5)

Burr & Forman on

Section 530 Relief - Employers that have workers which the employer classifies as “independent contractors” (Form 1099) risk having these workers reclassified by the IRS as employees. This is a major audit area for the...more

Foster Garvey PC

Golly Gee—the U.S. Tax Court Ruled That the Cost of a Taxpayer's Microsoft Xbox 360 and a Nintendo Wii Used by His Children Did...

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In 2015, the U.S. Tax Court issued its ruling in the case of David W. Laudon v. Commissioner, TC Summary Option 2015-54 (2015). The case may not raise or even resolve any novel tax issues, but it reminds us of what is...more

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