Straddle-Year Tax Debts in Bankruptcy: Does the King Get Paid First? [More with McGlinchey, Ep. 14]
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more
In an important decision regarding the scope of Most-Favored-Nation (“MFN”) clauses in investment treaties, the Svea Court of Appeal on 12 November 2024 annulled the Partial Award on Jurisdiction and Admissibility in Zaza...more
The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments...more
On 9/19/24, the IRS issued a warning to taxpayers regarding OIC (Offer in Compromise) Mills that are taking advantage of taxpayers. OIC Mills promoters claim that their services are necessary to resolve taxpayer unpaid taxes...more
Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more
Minnesota Attorney General Keith Ellison has secured a court order against Wall & Associates, Inc., and associated individuals (collectively “Wall”) for their involvement in an alleged tax debt settlement scheme in violation...more
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
On 8/23/24, the IRS Report Card was released via Notice IR-2024-223 regarding the progress and improvements made possible by the Inflation Reduction Act (“IRA”). The IRS Report Card states that the IRA has made it possible...more
On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more
In Ryckman v. Commissioner, the U.S. Tax Court tackled an issue of first impression: whether it has jurisdiction over a case challenging the denial by the Internal Revenue Service (“IRS”) of a collection due process (“CDP”)...more
In a landmark shift towards protecting delinquent taxpayer’s interest in surplus funds generated from tax lien foreclosures, Massachusetts enacted a law as a part of its 2025 budget to revise the way surplus funds are...more
El 5/4/24, el Departamento del Tesoro de EE. UU. y el IRS describieron los logros alcanzados en el primer año de implementación del Plan Operativo Estratégico, una hoja de ruta integral para transformar el IRS utilizando los...more
On 5/4/24, the U.S. Department of the Treasury and the IRS outlined the accomplishments achieved in the first year of implementation of the Strategic Operating Plan, a comprehensive roadmap to transform the IRS using...more
En su mayor parte, los contribuyentes no quieren recibir correo del IRS ni abrir correo del IRS. Es por eso por lo que el IRS emitió el Consejo Fiscal (“Tax Tip”) 2024-45 el 6 de mayo de 2024 para informar a los...more
For the most part, Taxpayers do not want to receive mail from the IRS or open mail from the IRS. This is why IRS issued Tax Tip 2024-45 on May 6, 2024 to let taxpayers know what taxpayers should do if they receive mail from...more
El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more
IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more
On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more
On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more
On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more
In an unpublished opinion released on May 12 in Grayson Dailey v. SC Home Holdings, LLC (Op. No. 2024-UP-164), the South Carolina Court of Appeals upheld the tax sale of real property in Lexington County over the objection of...more
El 4/4/24, la Oficina de Cumplimiento de la Comisión Federal de Comunicaciones (“FCC”) emitió una carta de cese y desista contra Veriwave Telco debido a una campaña ilegal de llamadas “Robocall” perteneciente a un “Programa...more
On 4/4/24, the Federal Communication Commission (FCC) Enforcement Bureau issued a cease-and-desist letter against Veriwave Telco due to an illegal robocall campaign pertaining to a “National Tax Relief Program.” The FCC also...more
I previously posted about the process for requesting the subordination of an IRS lien – that post can be found here. However, as noted in that post, subordination is primarily useful in cases where a taxpayer intends to keep...more