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Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
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Nonprofit Basics: Federal Tax Filing Deadlines and Penalties
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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
Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more
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
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
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
On March 5, 2024, the U.S. Department of Treasury and Internal Revenue Services (IRS) released final regulations regarding the direct payment election under the Inflation Reduction Act of 2022 (IRA), a tax credit monetization...more
The proposed regulations adopt the Department of Labor’s published rates for prevailing wages for the relevant type of construction in the geographic location of the project. The proposed regulations provide additional...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more
On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more