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Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Holland & Knight LLP

IRS Notifies Thousands of Taxpayers After Personal Information Disclosed

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The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more

Alston & Bird

Plan in Advance: Deferred Revenue Tax Considerations in M&A Transactions

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Our Federal Tax Group discusses the tax treatment of deferred revenue or advance payments in M&A transactions. The tax treatment of deferred revenue differs from the treatment for financial accounting purposes....more

Seward & Kissel LLP

Private Equity Investment into NFL Teams: Tax and Business Considerations

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Owning an NFL team is no longer a fantasy. The National Football League (the “NFL” or the “League”) voted to allow minority stakes to be sold to private equity firms (“PE”). However, according to NFL.com, “an executive from...more

Hinshaw & Culbertson LLP

Updated FinCEN FAQs Provide Three Important Clarifications on Reporting Obligations Under the Corporate Transparency Act (CTA)

The Corporate Transparency Act (the CTA) went into effect earlier this year, although many uncertainties about the CTA's application still remain. To help remedy those uncertainties, the Financial Crimes Enforcement Network...more

ArentFox Schiff

IRS Data Leak Hits Home: Actions for Taxpayers in the Wake of the Littlejohn IRS Data Breach

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The Internal Revenue Service (IRS) has begun the process of informing over 70,000 taxpayers that their confidential tax information was leaked in a widespread breach by a former IRS contractor. Those impacted should take...more

ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

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Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Weber Gallagher Simpson Stapleton Fires &...

Child Tax Credit Modifications: Implications for Divorcing Couples

Parties going through a divorce often negotiate the child tax credit and dependency exemptions in either support or divorce court. The Child Tax Credit has been modified several times in the past few years and once again may...more

Allen Barron, Inc.

Have You Disclosed Offshore Cryptocurrency and NFT Activities to the IRS?

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Have you fully disclosed offshore cryptocurrency and NFT activities to the IRS? Earlier this month, the US Department of Justice announced the indictment of a Texas man for tax returns that were inaccurate, incomplete, or...more

Allen Barron, Inc.

IRS Tax Refunds are Lower for Tax Year 2023 Thus Far

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Did you know IRS tax refunds are lower for tax year 2023 thus far when compared to the same point a year ago? While the IRS just began accepting tax returns for tax year 2023 on January 29 of this year, there is already one...more

Buckingham, Doolittle & Burroughs, LLC

Employee Retention Credit on the Chopping Block as Congress Mulls Tax and Spending Bills

The Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) would terminate the employee retention credit (ERC) for claims filed after January 31, 2024. Initially authorized by the CARES Act to incentivize...more

Allen Barron, Inc.

IRS to Leave More in Our Paychecks in 2024

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Is it possible for the IRS to leave more in our paychecks in 2024? What has changed for the 2024 federal income tax brackets and how will these apply to the tax return(s) you’ll file in 2025?...more

Herbert Smith Freehills Kramer

Pandemic-Related Employee Retention Credits: Increasing IRS Scrutiny and Related M&A Considerations

The IRS continues to focus on combating perceived fraudulent claims relating to the COVID-19 pandemic-era Employee Retention Credits (ERCs). On Oct. 19, the IRS announced a special process allowing taxpayers to withdraw...more

Bowditch & Dewey

Massachusetts Tax Reform Enacted – Estate Tax Exemption Increase and Other Help for Residents

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The long-awaited Massachusetts tax reform package was signed by Governor Maura Healey on Wednesday, October 4, 2023. Among the provisions: Estate Tax Reform: Establishes a non-refundable credit of $99,600 for each estate,...more

ArentFox Schiff

Investigations Newsletter: Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy

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Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy - A federal jury in the Western District of Arkansas convicted four men of conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money...more

DarrowEverett LLP

How IRS Is Cracking Down on Employee Retention Tax Credit Fraud

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The Internal Revenue Service (“IRS”) has recently devoted great attention to detecting, investigating, and prosecuting fraud, particularly as it relates to the Employee Retention Tax Credit (“ERC”) post-COVID. On a webinar...more

Foster Garvey PC

When It Rains, It Pours in Washington State – The Washington Supreme Court Upholds the 2021 Enacted Capital Gains Tax

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It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more

Mintz

Lawsuit Challenging Taxation of Cryptocurrency Tokens Generated Through Staking Dismissed as Moot

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The early dismissal of a federal lawsuit that could have resolved whether certain cryptocurrency tokens can be taxed as federal income feels like business as usual for an industry accustomed to uncertainty. At issue in this...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Oberheiden P.C.

Crypto Tax Lawyers – 5 Things to Consider Before Hiring

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The IRS, Taxpayers, and Cryptocurrencies or virtual currencies - The Internal Revenue Service (“IRS”) issued its first guidance on cryptocurrencies— “virtual currencies''—in 2014, taking the position that crypto...more

Rivkin Radler LLP

Are The Feds Getting Ready To Kick Your “S”?

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Report Card- A couple of weeks ago, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report that presented the results of its review to determine whether the IRS’s “policies, procedures and,...more

Bowditch & Dewey

Cryptocurrency Tax Update

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The IRS continues its campaign against cryptocurrency investors and traders who evade income taxes on currency gains. As we wrote in 2016, the IRS was successful in compelling Coinbase, a large digital currency exchange, to...more

Rivkin Radler LLP

Tax Changes In The Offing? “Close Scrutiny” Of Business Owners’ Economic Benefits Remains A Constant

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I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more

Neal, Gerber & Eisenberg LLP

Deadline for Filing Extensions on Gift Tax Returns Is April 15

The Internal Revenue Service recently announced the federal income tax filing due date for individuals for the 2020 tax year will be extended automatically from April 15, 2021, to May 17, 2021.  However, this announcement did...more

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