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Taxation Penalties

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

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Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Walkers

Overview of the Cayman Islands Economic Substance requirements

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Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more

Frost Brown Todd

One Big Beautiful Bill Act Cuts the Power: Phase‑Outs, Foreign‑Entity Restrictions, and Domestic Content in Clean‑Energy Credits

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On July 4, 2025, President Trump signed H.R. 1—dubbed the One Big Beautiful Bill Act (OBBBA)—enacting significant modifications to clean‑energy credits previously enacted under the Inflation Reduction Act of 2022. OBBBA...more

Bilzin Sumberg

Playing Battleship with the IRS: Did They Sink Our Battleship?

Bilzin Sumberg on

In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”.  Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

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On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...more

DLA Piper

Belgian VAT Authorities Publish New Circular Letter Regarding Late Input VAT Recovery

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Seven years after relevant judgments from the CJEU, the Belgian VAT authorities now (broadly) allow the recovery of input VAT beyond the standard Belgian limitation period of three years, subject however to strict conditions....more

Wilson Sonsini Goodrich & Rosati

FAQs: UK Employee Equity Incentive Annual Reporting and EMI Notification Deadline Fast Approaching

Companies operating employee equity incentive arrangements in the UK, including companies incorporated or registered outside of the UK, are mandated to file an online annual return with HM Revenue & Customs (HMRC) no later...more

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

Bilzin Sumberg on

Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more

Freeman Law

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

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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

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

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The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Farrell Fritz, P.C.

Responding to NYS Tax Department Letters: Key Steps for Taxpayers

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Earlier this month, New York State Department of Taxation and Finance published a press release explaining what taxpayers should do when they receive a letter from the Tax Department. The press release outlined several...more

Proskauer - Tax Talks

IRS and Treasury Announce Withdrawal of Related Party Basis Shifting Regulations

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On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain...more

McDermott Will & Schulte

Let the Shakedowns Begin: Tax False Claims Legislation in California

Legislators in Sacramento, California, are mulling over one of the most (if not the most) troubling state and local tax bills of the past decade. Senate Bill (SB) 799, introduced earlier this year and recently amended,...more

Conyers

Common Reporting Standard: Regulatory Enforcement and Compliance for Cayman Entities

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The Cayman Islands Tax Information Authority (the “TIA”) is responsible for monitoring compliance and taking enforcement action with regards to the Common Reporting Standard (CRS), pursuant to the Tax Information Authority...more

Rivkin Radler LLP

New York Sales Tax: When a Responsible Person Acts Irresponsibly

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Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more

Freeman Law

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

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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

Vinson & Elkins LLP

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

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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

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

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Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

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